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BLM LIBRARY 



8801: 




U.S. DEPARTMENT OF THE INTERIOR 

Bureau of Land Management 



Final 



Oregon State Office 



May 1983 



Roseburg 

Timber Management 
Environmental 
Impact Statement 




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IN REPLY 
REFER TO: 



United States Department of the Interior 



BUREAU OF LAND MANAGEMENT 

Roseburg District Office 
777 N.W. Garden Valley Blvd. 
Roseburg, Oregon 97470 



1792 



May 27, 1983 



This is the final environmental impact statement (FEIS) on the 10-year timber 
management plan for the Douglas and South Umpqua Sustained Yield Units in the 
Roseburg District. The purpose of the statement is to disclose the probable 
environmental impacts and to assure that these impacts are considered along 
with economic, technical and other factors in the decisionmaking process. In 
using this analysis, readers should keep in mind that a FEIS is not the 
decision document. A final decision will ccme later and will be announced in 
a Record of Decision. 

A major issue of BIM's timber management throughout western Oregon has been 
concern regarding which uses of the forest land base were authorized under 
the terms of the O&C Act and subsequent legislation. In March 1983, 
following a major legal review and analysis of these authorities, BLM 
Director Robert Burford issued a new O&C Forest Resources Policy defining the 
agency position for the management of forest lands in western Oregon. The 
proposal developed from application of the policy (see Appendix A) is 
identified in the statement as the New Preferred Alternative (Alternative 9). 

This EIS is being released in accordance with a schedule contained in the 
agreement of February 19, 1976, relative to the litigation in the U.S. 
District Court for the District of Columbia, entitled Natural Resource 
Defense Council, Inc., et al . v. Thomas S. Kleppe, et al. , Civil No. 75-1861. 
Due to the addition of a New Preferred Alternative (Alternative 9), a 60-day 
comment period on the FEIS is established. Comments received by the Roseburg 
District before August 1, 1983 will be considered prior to the release of a 
Roseburg Record of Decision. 

Sincerely yours, 

l> James E. Hart 
District Manager 




Bureau of Land Management 

Library 

Bldg. 50. r ~ ral Center 

Oenver, CO 80225 



0123-^ 



S3 



U.S. DEPARTMENT OF THE INTERIOR 

Bureau of Land Management ^ ~J 

BUi Library ~ §> g 

D-653A, Buildirg50 
Denve fi ec - al canter 
P.O. Bcxi,6o47 
Denver, CO 80225-0047 



FINAL 



ENVIRONMENTAL 
IMPACT STATEMENT 



Roseburg 
Sustained Yield Units 

Ten-Year 

Timber Management Plan 

eauofU. 
UbjW Cen ter 

Denver, CO 80225 ^ 



Prepared By 

U.S. DEPARTMENT OF THE INTERIOR 

BUREAU OF LAND MANAGEMENT 

1983 



State Director, Oregon State Office 



Roseburg Proposed Timber Management 



VICINITY MAP 



ROSEBURG SYUS 




Draft ( ) Final (x) Environmental Impact Statement 
Department of the Interior, Bureau of Land Management 

1. Type of Action: Administrative (x) Legislative ( ) 

2. Abstract: This EIS describes and analyzes the environmental impacts of implementing an updated 10-year 
(1984-1993) timber management plan for the 423,896 acres of public land in the Douglas and South Umpqua 
Sustained Yield Units in the Roseburg District, Oregon. The Bureau of Land Management is responsible for 
managing timber on public lands under the principle of sustained yield. Nine alternatives are described and 
analyzed for environmental impacts. The alternatives analyzed include: 1) Maximum Timber Production, 2) 
Strong Emphasis on Timber Production, 3) Lower Average Minimum Harvest Size, 4) the Original Proposed 
Action, 5) No Action, 6) Habitat Diversity, 7) No Herbicides, Fertilizer or Allowable Cut Effect for Genetics, 
8) Emphasis on Protection of Natural Values, 9) New Preferred Alternative. Specific timber management 
components of the alternatives include road construction, timber harvest, site preparation, reforestation, 
plantation protection, precommercial thinning, fertilization and control of competing vegetation. 
Significant environmental impacts of the New Preferred Alternative include wildlife habitat modification; 
soil erosion, landsliding and stream sedimentation; and increased timber harvest and employment. 

3. Due to the addition of a New Preferred Alternative, a 60-day comment period on the FEIS is established. 
Comments will be accepted by the Roseburg District Manager until August 1, 1983, at the address listed 
below. 

4. For further information contact: 

Bob Alverts, Planning Coordinator 
Bureau of Land Management 
Roseburg District Office 
777 NW Garden Valley Blvd. 
Roseburg, Oregon 97470 
Telephone (503) 672-4491 



Summary 



Introduction 

This environmental impact statement (EIS) 
describes and analyzes the environmental impacts 
of implementing an updated 10-year (1984-1993) 
timber management plan for the Douglas and 
South Umpqua Sustained Yield Units in the 
Roseburg District, Oregon. Hereafter, the 
Sustained Yield Units will be referred to as the 
Roseburg Sustained Yield Units or simply the 
SYUs. This EIS applies to actions proposed for the 
423,896 BLM-administered acres within the 
combined SYUs. These are primarily revested 
Oregon and California Railroad (O&C) lands and 
reconveyed Coos Bay Wagon Road (CBWR) lands. 
There are also scattered remnants of the original 
Public Domain (PD) lands. 

Approximately 402,000 acres of the land area in 
the Roseburg SYUs is commercial forest land, with 
an additional 21,900 acres in non-commercial 
forest or non-forest categories. To the extent 
possible, non-forest, non-intensive commercial 
forest land and withdrawn areas have been used to 
partially provide a variety of forest resource uses, 
including habitat for threatened and endangered 
species and other wildlife, as well as watershed, 
recreation, scenic and other values. 

In accordance with the National Environmental 
Policy Act, this EIS identifies impacts on the 
natural and human environment associated with 
nine alternatives. The EIS is based primarily on 
data collected and analyzed through the Bureau 
planning system which included extensive public 
involvement. Alternative 9, developed to meet new 
policy for O&C lands, is the Preferred Alternative. 
Eight other alternatives have been identified, 
providing a wide range of options for review and 
consideration. A basic assumption incorporated 
into the analysis is that sufficient funding and 
personnel will be available for implementation of 
any alternative. 



Alternatives 

Timber harvest under all alternatives would 
be accomplished predominately by clearcutting, 
with some single tree selection. Intensive timber 
management treatments would include 
construction of logging roads, site preparation 
with burning, mechanical means and herbicide 
application, planting coniferous trees (including 
genetically improved stock), plantation protection, 
plantation maintenance and release with 
herbicides or manual means, precommercial 
thinning and fertilization. Alternative 7 excludes 
the use of herbicides and fertilization. 

Variables among alternatives include amounts of 
land allocated to timber production, types and 
amounts of intensive management practices, 
harvest scheduling and constraints on timber 
harvest to benefit other resource values. The 
minimum size of timber available for final harvest 
also varies by alternative. Harvest at the minimum 
size, reached in 40 to 50 years for all alternatives 
except 8, would begin in approximately the fifth 
decade. Harvest at the minimum size would 
continue for 6 to 23 decades, depending on the 
alternative. The proposed alternatives are: 

1. Maximum Timber Production. This alternative 
maximizes timber production while meeting legal 
requirements to protect federally listed threatened 
and endangered species and cultural resources. It 
would allocate 386,622 acres of commercial forest 
land to intensive timber management and produce 
an annual timber sale program of 289 MM bd. ft. 
Operational and spatial constraints on timber 
harvest and stand regeneration would be 
minimized. The average minimum size of trees in 
stands available for final harvest would be 12.7 
inches diameter breast height (dbh), normally 
reached in 40 years. 



2. Emphasis on Timber Production. This 
alternative would allocate 360,580 acres of 
commercial forest land to intensive timber 
management with an additional 24,786 acres 
managed under modified area control. This would 
produce an average timber sale program of 267 
MM bd. ft. annually. A longer harvest cycle 
(average of 250 years) under modified area control 
would provide timber harvest while protecting 
some resources in riparian areas, wildlife habitat 
and visual corridors. The average minimum 
diameter of trees in stands available for final 
harvest would be 14.4 inches dbh, normally 
reached in 50 years. 

3. Lower Average Minimum Harvest Size. This 
alternative allocates 333,319 acres of commercial 
forest land to intensive timber management with 
an additional 52,047 acres managed under 
modified area control. Under the intensive timber 
production base, the average minimum diameter of 
trees in stands proposed for final harvest would be 
12.7 inches dbh, normally reached in 40 years. 
This alternative would produce an average timber 
sale program of 256 MM bd. ft. annually. 

4. Original Proposed Action. This alternative is 
identical to Alternative 3 except that minimum 
harvest size is increased, shortening the time to 
achieve a regulated forest. The minimum average 
tree diameter in stands selected for final harvest 
would be 14.4 inches dbh compared to 12.7 inches 
dbh under Alternative 3. The minimum harvest age 
would be 50 years, providing an average annual 
timber sale program of 249 MM bd. ft. 

5. No Action (No Change). A required alternative 
in the EIS, this would constitute a continuation of 
the present annual timber sale program of 201 MM 
bd. ft. on 390,984 acres. It would continue the 
intensive management practices and constraints 
identified in the 1972 allowable cut determination. 
Non-timber allocations, limited to 400 acres, 
include buffers for recreation areas and sensitive 
visual corridors. Streamside buffers totaling 8,070 
acres would be provided along third order and 
larger streams. 

6. Habitat Diversity. This alternative emphasizes 
protection of natural and cultural values, while 
accommodating production of timber. It would 
allocate 222,357 acres to intensive forest 
management with an additional 119,924 acres 
managed under longer harvest cycles. The annual 
timber sale program would be 183 MM bd. ft. The 
minimum average diameter of trees in the intensive 
timber management stands available for final 
harvest would be 14.4 inches dbh, normally 
reached in 50 years. 

7. No Herbicides, Fertilizer or Allowable Cut Effect 
for Genetics. This alternative is similar to 
Alternative 4 in timber base and treatments, except 
that herbicides and fertilizer would not be used. It 
would provide for continued planting of 



genetically improved trees, but the allowable cut 
computation would not take credit for expected 
growth increases. The average timber sale 
program would be 176 MM bd. ft. annually. The 
minimum average diameter of trees in stands 
available for final harvest would be 13.6 inches 
dbh, normally reached in 50 years. Vegetation 
management practices in lieu of herbicides would 
be prescribed to approximately the same dollar 
level of investment as would be used for fertilizer 
and herbicide applications. 

8. Emphasis on Protection of Natural Values. 

Under this alternative, protection is provided for a 
variety of wildlife habitats, sensitive botanical 
species, cultural resources, visual resources, 
research natural areas, riparian areas and 
dispersed recreational activities. Approximately 
262,436 acres of commercial forest land would be 
included in the constrained timber base. Minimum 
harvest ages would vary from 60 to 350 years. This 
would produce an annual timber sale program of 
84 MM bd. ft. Fifteen-year spacing between harvest 
areas would be employed. Timber harvest would 
be allowed only when direct benefit to the 
protected resources would result. This is 
considered to be a full ecosystem alternative. 

9. New Preferred Alternative. This alternative is a 
modification of the Original Proposed Action 
(Alternative 4) resulting from application of the 
new O&C Forest Resources Policy. The alternative 
seeks a high level of timber production (247 MM 
bd. ft. /year) while managing for a variety of natural 
values and recreation opportunities. This 
alternative would allocate 331,637 acres of 
commercial forest land to intensive management 
with an additional 35,868 acres managed under 
modified area control. An estimated 23,565 acres 
of commercial forest land would be withdrawn to 
protect riparian areas, bald eagles, Research 
Natural Areas, botanical species and cultural 
resources. 



Environmental 
Consequences 
Air Quality 



The major impact on air quality would be 
from slash burning. Particulate emissions range 
from 1,142 tons to 3,828 tons per year. 

Soils 

Impacts to soils are mainly due to road 
construction, landslides and compaction. 
Alternative 1 has the greatest long-and short-term 
impacts while Alternative 8 has the least. 
Production losses range from 2,647 equivalent 
acres under Alternative 8 to 9,136 equivalent acres 
under Alternative 1. Less significant impacts 
include nutrient losses, dry ravelling and topsoil 
removal. 



Water Resources 

Sediment yield would increase under 
Alternatives 1 to 3, decrease under Alternatives 4, 
6, 7, 8 and 9. Water yield increases are expected 
under Alternatives 1 to 5 and 9, decreases under 
Alternatives 6, 7 and 8. Water temperature would 
increase under Alternative 1. Based on the sample 
5-year sale plan, timber harvest activities planned 
in four municipal watersheds would increase water 
yield and sedimentation. 



Vegetation 



Alterations to plant community structure and 
longevity would be the most significant impacts to 
vegetation on lands scheduled for timber harvest. 
Acres scheduled for timber harvest over the next 
decade would range from 74,807 under Alternative 
1 to 19,915 under Alternative 8. Mature and old- 
growth forest communities would be converted to 
early successional stage communities as slow- 
growing timber stands are replaced by young, fast- 
growing stands. Diversity and complexity of plant 
communities would diminish as maximum growth 
of commercial conifers is emphasized. Changes in 
plant communities and habitat could eliminate 
some plant species in the long term. Plant habitat 
altered by herbicides would increase under all 
alternatives except 7 and 8. Permanent road 
construction during the decade would eliminate 
vegetation from public land, ranging from 5,568 
acres under Alternative 1 to 1,662 acres under 
Alternative 8. 

Animals 

Habitat diversity would increase in the 
short term. However, in all alternatives except 8, 
there would be significant long-term adverse 
impacts to some animal populations due to a 
decrease in habitat diversity and, in particular, a 
reduction in the mature and old growth 
components of the forest. Simplification of 
habitats due to intensive forest management 
practices would add to this impact. 

Riparian habitat would be adequately protected by 
Alternatives 6, 8 or 9, but would be adversely 
impacted by all other alternatives. Increases in 
sediment yield in Alternatives 1 through 3 and 
increases in water temperature in Alternative 1 
would negatively impact fish. Fish would increase 
in Alternatives 4, 6, 7, 8 and 9. 

Snag-dependent wildlife would be greatly reduced 
in the long term, but impacts would be minimal in 
the short term. In the long term, elk numbers are 
expected to decline in all alternatives except 8. Elk 
numbers would increase in the short term in all 
alternatives. 

There would be no known adverse impacts to any 
species listed by the Federal Government as 
threatened or endangered. The northern spotted 



owl, listed by the State of Oregon as threatened, 
may be adversely impacted in the long term by all 
alternatives except 8. 

Recreation 

The impacts of timber management operations 
would be both beneficial and adverse, depending 
on the recreational experience desired. Visitor use 
increases or reductions may occur in certain areas 
as a result of impacts to specific recreational 
experiences. 

Impacts would depend upon the approach taken to 
meet recreational needs. For the long term, 
Alternative 5 would fall short of meeting demand in 
many activities with identified area and facility 
needs. Alternative 1 emphasizes those activities 
having minimal impact on the commercial timber 
base and would not provide for new developed 
sites. Alternatives 2, 3, 4, 7, and 9 provide a variety 
of opportunities to meet most needs. Alternatives 6 
and 8 emphasize dispersed activities, natural areas 
and the opportunity for site development, although 
Alternative 8 would not meet the need for off-road 
vehicle areas and trails. In the long term, area-wide 
elk hunting opportunities are expected to be 
adversely impacted under all alternatives except 6 
and 8, while fishing opportunities are expected to 
be adversely impacted under Alternatives 1 
through 3. 

Cultural Resources 

Appropriate measures would be taken to 
identify and protect cultural sites prior to ground- 
disturbing activities under all alternatives. 
Undiscovered cultural sites would be susceptible 
to considerable alteration and damage. Once a site 
is found, however, mitigation measures will be 
instituted to minimize or avoid damage. Under all 
alternatives, significant sites identified before, 
during and after logging would be managed to 
protect scientific and/or interpretive values. 

Visual Resources 

Under Alternative 8, visual resource 
conditions (scenic quality) would improve. Under 
Alternative 6, most highly scenic and/or sensitive 
areas would be protected with slight adverse 
impacts in some areas of the SYUs. Adverse visual 
impacts under Alternatives 2, 3, 4, 7, and 9 would 
be low to moderate. Many highly scenic and/or 
sensitive areas would be protected. 

Under Alternatives 1 and 5, adverse visual impacts 
would be high with some protection provided for 
certain highly scenic and/or sensitive areas, 
primarily essential bald eagle habitat and existing 
recreation sites. 



Areas of Critical Environmental 
Concern 

Area of Critical Environmental Concern 
(ACEC) designation would provide guidelines to 
help achieve resource protection in those areas 
designated. All alternatives except 5 provide some 
level of ACEC designation greater than the 
existing situation. Designation ranges from four 
areas (600 acres) under Alternative 1 to seven 
areas (3,100 acres) under Alternatives 6 and 8. 

Special Areas 

Alternative 1 allows for designation of 
those areas which would not affect the commercial 
timber production base of the SYUs. Alternatives 
2, 3, 4, 7, and 9 allow for designation of those 
areas identified as having significant natural values 
for science, recreation or education. Alternative 5 
provides no additional natural area designation 
above that under the existing situation. 
Alternatives 6 and 8 emphasize the study and 
designation of natural areas. However, some sites 
(e.g., Red Pond, Dompier Creek Landslide) with 
natural and environmental education values may 
be adversely impacted if they are not designated 
or otherwise protected. 

Human Health 

The possibility of human health being 
impacted by the use of herbicides is related to the 
toxicity of the herbicide, the likelihood of 
exposure, and resulting dosage received. Based on 
current knowledge and the low risk of exposure on 
BLM-treated acres, an unreasonable risk to human 
health from continued, careful use of herbicides is 
unlikely. Herbicides would not be used under 
Alternative 7. 



Energy Use 



Fossil fuel energy would be consumed in all 
phases of the 10-year timber management plan. 
The annual energy consumption ranges from 218 
billion Btu's (Alternative 8) to 834 billion Btu's 
(Alternative 1). The annual energy consumption 
attributable to the New Preferred Alternative 
(Alternative 9) would be approximately 716 billion 
Btu's. 

Socioeconomics 

Compared to timber harvest levels in Douglas 
County from 1976-1980, Alternatives 1 through 5 
and 9 would increase employment in the timber 
industry and total local employment and earnings. 
The New Preferred Alternative (Alternative 9) 
could result in an increase of 440 timber industry 
jobs and 1,023 jobs in total. The greatest increase 
in jobs would be the result of Alternative 1 , 
yielding 751 timber industry jobs and 1,746 total 
jobs. Alternative 8 would result in a net loss of 766 
timber industry jobs and 1,780 total jobs. 



Compared with continuation of the current timber 
management program, Alternatives 1 through 4 
and 9 add economic activity. In this comparison, 
the New Preferred Alternative (Alternative 9) would 
add 340 timber industry jobs and 791 jobs in total. 
At the extremes, Alternative 1 could stimulate up 
to 1,514 new jobs while Alternative 8 could impact 
the regional economy by a reduction of 2,012 jobs. 

Public revenues would be increased or maintained 
for Alternatives 1 through 5 and 9 and decline for 
Alternatives 6 through 8. 



Table of Contents 



Page 

Summary 3 

Chapter 1 Description of Alternatives Including the Proposed Action 11 

Purpose of and Need for the Action 11 

Alternatives 12 

Alternative 1 - Maximum Timber Production 13 

Alternative 2 - Strong Emphasis on Timber Production 13 

Alternative 3 - Lower Average Minimum Harvest Size 13 

Alternative 4 - The Original Proposed Action 15 

Alternative 5 - No Action 15 

Alternative 6 - Habitat Diversity 15 

Alternative 7 - No Herbicides, Fertilizer or Allowable Cut Effect for Genetics 15 

Alternative 8 - Emphasis on Protection of Natural Values 15 

Alternative 9 - New Preferred Alternative 16 

Forest Management Treatments and Design Elements 16 

Transportation System 17 

Timber Harvest 17 

Site Preparation 17 

Planting 19 

Plantation Protection 19 

Plantation Maintenance and Release 19 

Precommercial Thinning 20 

Fertilization 20 

Comparison of Impacts 20 

Implementation 20 

Final Decision 20 

Monitoring and Studies 20 

Requirements for Further Environmental Assessment 22 

Interrelationships 22 

Federal Agencies 22 

State and Local Governments 23 



8 

Page 

Chapter 2 Affected Environment 27 

Climate and Air Quality 28 

Geology and Topography 29 

Soils 29 

Water Resources 30 

Vegetation 35 

Terrestrial Vegetation 35 

Wetland and Aquatic Vegetation 38 

Sensitive, Threatened and Endangered Plants 38 

Animals 39 

Terrestrial Animals 39 

Fish 41 

Threatened and Endangered Animals 42 

Recreation 43 

Cultural Resources 43 

Prehistoric Sites 44 

Historic Sites 44 

Paleontologic Sites 44 

Visual Resources 45 

Wilderness Values 45 

Areas of Critical Environmental Concern 45 

Special Areas 45 

Socioeconomic Conditions 46 

Timber Industry 53 

Fishing, Hunting and Other Recreation 53 

Social Concerns 53 

Chapter 3 Environmental Consequences 59 

Introduction 59 

Impacts on Air Quality 60 

Conclusions 61 

Impacts on Soils 61 

Conclusions 63 

Impacts on Water Resources 63 

Water Quantity 63 

Water Quality 63 

Municipal Watersheds 65 

Conclusions 65 

Impacts on Vegetation 65 

Terrestrial Vegetation 66 

Threatened or Endangered Plants 67 

Conclusions 68 

Impacts on Animals 68 

Terrestrial Vertebrates 68 

Fish 74 

Threatened and Endangered Animals 75 

Conclusions 76 

Impacts on Recreation 77 

Conclusions 78 

Impacts on Cultural Resources 78 

Conclusions 79 

Impacts on Visual Resources 79 

Impacts on Areas of Critical Environmental Concern 81 

Impacts on Special Areas 81 

Impacts on Energy Use 81 

Impacts to Human Health 82 

Impacts on Socioeconomic Conditions 84 

Chapter 4 Consultation and Coordination of the Draft 

Environmental Impact Statement 89 

Statement 89 

List of Agencies, Organizations and Persons to Whom Copies of the Statement are Sent 149 

List of Preparers 1 50 

Appendices 153 



9 

Page 

Glossary 1 89 

References Cited 197 

Index 205 



Tables 



1-1 Land Jurisdiction in Acres by County within Roseburg Sustained Yield Units 13 

1-2 Comparison of Proposed Action and Alternatives by Treatment — First Decade 14 

1-3 Derivations of Timber Production Base Acreage 14 

1-4 Estimated Ten-Year Use of Herbicides 18 

1-5 Summary of Impacts 21 

1-6 Relationship of Roseburg EIS Alternatives to LCDC Statewide Goals 24 

1-7 Consistency of the Roseburg Alternatives with the Basic Objectives of the Forestry Program 

for Oregon 25 

1-8 Consistency of the Alternative with State of Oregon Wildlife Goals 26 

2-1 Total Suspended Particulates in Roseburg 28 

2-2 Slash Smoke Problems in Douglas County 29 

2-3 Bared Soils and Rose Surfaces 30 

2-4 Fragile and Problem Soils 30 

2-5 Severe Water Quality Problems 35 

2-6 Streamf low Data 36 

2-7 Sediment Discharge Data 37 

2-8 Existing Forest Habitat Stratification of Entire Roseburg Area 38 

2-9 Sensitive Species Currently under Review for Possible Listing 39 

2-10 Habitat Structure of Forest Lands in the SYUs 40 

2-1 1 Salmonoid Fish and Habitat Populations 42 

2-12 Threatened and Endangered Species of the SYUs 42 

2-13 Estimated Current and Projected Visitation Attributed to Major Recreation Activities 44 

2-14 Nominated and Potential Areas of Critical Environmental Concern 46 

2-15 Population, 1960-1980 49 

2-16 Components of Population Change, 1970-1980 49 

2-17 Average Size and Recent Growth of the Labor Force and Employment in Industries 50 

2-18 Total and Rate of Growth of Labor and Proprietors' Income in Selected Industries 

Affected by Timber Management in the Roseburg District 50 

2-19 County Revenue Sources as a Percentage of Total Revenues and County Revenues 

Per Capita for Fiscal Years 1977-1978 51 

2-20 O&C Revenue Distribution to Counties Expressed as Property Tax Rate Equivalent 

and as a Percent Supplement to Total Levy, Fiscal Years 1977-1980 52 

2-21 In-Lieu Tax Payment on CBWR Lands Administered by BLM in Douglas County 52 

2-22 Timber Harvest by Ownership Class, Douglas County 53 

2-23 Dependency of Log Processors in Oregon and Douglas County on BLM Timber 54 

2-24 Harvest Sales and Receipts, BLM Timber in the Roseburg District 54 

2-25 Average Annual Local Economic Effects of Timber Management on Lands 

Administered by the Roseburg District 55 

2-26 Local Economic Effects of Fisheries, Terrestrial Wildlife and General Recreation 56 

2-27 Changes Desired by Survey Respondents in the Use of Federal Lands 57 

3-1 Average Emission Components from Slash Burning 61 

3-2 Estimated Loss of Productivity During First Decade 62 

3-3 Expected Nutrient Losses from Timber Harvesting and Slash Burning 62 

3-4 Estimated Annual Water Yield from BLM-Administered Land, End of First Decade 63 

3-5 Estimated Sediment Through Buffer Strips 64 

3-6 Estimated Sediment Yield from BLM-Administered Land, End of Decade 65 

3-7 Proposed Activities in Municipal Watersheds Based on the Sample Five Year 

Timber Sale Plan 65 

3-8 Approximate Acres of BLM-Administered Timber Lands and Percent of Change 

after One Decade 66 

3-9 Acres of Old Growth and Percent Change from Existing on BLM-Administered Lands 

Remaining at the End of Each Decade 69 

3-10 Estimated Elk Population Changes on BLM-Administered Lands in the Tyee Area 71 

3-1 1 Long-Term Snag Density 72 

3-12 VRM Classes 80 

3-13 Potential Impacts of the Sample Five-Year Timber Sale Plan on Visual Resources 80 

3-14 Potential Impacts to Areas Qualified for ACEC Designation 82 



10 

Page 

3-15 Potential Impacts to Special Areas 82 

3-16 Estimated Annual Energy Consumption 83 

3-17 Herbicide Toxicity 83 

3-18 Short-Term Impacts Compared to No Action Condition on Local Employment and 

Earnings Related to Timber Harvest 85 

3-19 Projected Distribution of O&C Payments from SYUs to Counties by Alternative 86 

3-20 Projected Distribution of Severance Taxes on CBWR Lands by Alternative 86 



Figures 



Vicinity Map 7 

1-1 Roseburg SYU-EIS Area Inside Back Pocket 

2-1 Physiographic Province 31 

2-2 General Soils 33 

2-3 Visual Resource Management 47 

2-4 Annual Average Lumber and Wood Products Employment; Douglas County, Oregon 1970-1980 56 

A-1 Western Oregon Tree Seed Zones 157 

C-1 Allowable Cut Effect 171 

C-2 Allowable Cut Determination Process 172 



11 



Chapter 1 Description of 
Alternatives Including the 
Proposed Action 




Purpose of and Need for the 
Action 

The Bureau of Land Management (BLM) proposes 
to implement, beginning October 1, 1983, an 
updated 10-year timber management plan for the 
and South Umpqua Sustained Yield Units in the 
Roseburg Douglas District, Oregon (Figure 1-1, 
folded map in the back cover pocket). The 
Douglas and South Umpqua Sustained Yield Units 
will be referred to in this document as Roseburg 
Sustained Yield Units (SYUs). These are primarily 
revested Oregon and California Railroad (O&C) 
and reconveyed Coos Bay Wagon Road (CBWR) 
grant lands. There are also scattered remnants of 
the original Public Domain (PD) lands. In 
accordance with the National Environmental 
Policy Act (NEPA), this EIS identifies impacts on 
the natural and human environment associated 
with nine alternatives. The 10-year timber 
management plan for the two SYUs provides 
direction for management of these lands as 
required by the acts mentioned below. 

The Bureau's principal authority and direction to 
manage the O&C and CBWR grant lands is found 
in the O&C Act of 1937 (50 Stat. 874; 43 U.S.C. 
1181a., et seq.). The disposition of funds derived 
from the CBWR grant lands is described in an act 
approved on May 24, 1939 (43 U.S.C. 1181f-l et 
seq.). Under these acts, O&C and CBWR lands 



12 



classified as timberlands are to be managed under 
sustained yield principles in order to provide a 
permanent source of timber supply, watershed 
protection, stream flow regulation and recreational 
facilities. Intermingled PD lands were brought 
under sustained yield management principles by 
the Bureau's 1962 application to withdraw these 
lands from entry under all public land laws except 
certain disposal acts. Withdrawal was completed 
by Public Land Order 5490 in 1975 (40 FR 7450). In 
addition, many activities of the BLM are governed 
by the Federal Land Policy and Management Act 
of 1976 (90 Stat. 2743, 43 U.S.C. 1701). This law, 
often referred to as FLPMA, established policy for 
BLM administration of public lands under its 
jurisdiction. 

Notwithstanding any provision of FLPMA, in the 
event of conflict with or inconsistency between 
FLPMA and the O&C Act of August 28, 1937 (50 
Stat. 874; 43 U.S.C. 1181a-1181j), and the Act of 
May 24, 1939 (43 USC 1181M et seq.), insofar as 
they relate to management of timber resources 
and disposition of revenues from lands and 
resources, the 1937 and 1939 acts shall prevail. 

The O&C Forest Resources Policy to be used in 
formulating decisions for BLM-administered forest 
lands in western Oregon was approved by the 
Director in March 1983. A copy of the policy is 
included in this EIS in Appendix A. To respond to 
the policy, an additional alternative has been 
included in this FEIS and is designated BLM's New 
Preferred Alternative (Alternative 9). 

During an EIS scoping meeting held in Roseburg, 
Oregon (October 19, 1981), participants were 
asked to identify issues and alternatives to be 
addressed in this EIS. Chapter 1 includes 
alternatives identified during scoping and 
considered appropriate for full analysis. 
Alternatives identified but not considered 
appropriate for full analysis, and the rationale for 
these determinations are presented in Appendix B, 
which summarizes the scoping meeting. A 
discussion of the economic efficiency of the 
timber management program for the Original 
Proposed Action and Alternative 9 (New Preferred 
Alternative) is included in Appendix B. 

During the planning process, criteria (Appendix C) 
were used to evaluate alternatives and select a 
proposed land use allocation alternative. The 
results of this evaluation, combined with public 
input, led to the original proposed land use 
alternative, Alternative 4 in this EIS. 

Appendix C also addresses inventory methods 
used to arrive at the timber production base, 
allowable cut determination and other land use 
allocations. Acreages for land use allocations by 
alternative are shown in Appendix C, Table C-2. 



The alternatives prepared for the SYUs identify 
various timber harvest levels, management 
practices and mitigating measures to protect the 
land and other resources. This information is 
described in detail in the remainder of this 
document. 

Alternatives 

Planning for the Roseburg Sustained Yield 
Units (SYUs) focused on the 423,896 acres of 
public land administered by BLM. Except for 280 
acres in Lane County and 400 acres in Jackson 
County, all lands are in Douglas County. BLM 
administers 29 percent of the total land within the 
Roseburg SYUs (Table 1-1). 

There are nine alternatives, including the 
Original Proposed Action (Alternative 4) and the 
New Preferred Alternative (Alternative 9), for 
which impacts will be analyzed in Chapter 3: 

1. Maximum Timber Production (Max. Tbr.) 

2. Emphasis on Timber Production (Emp. Tbr.) 

3. Lower Average Minimum Harvest Size (Lo MHS) 

4. Original Proposed Action (OPA) 

5. No Action 

6. Habitat Diversity (HD) 

7. No Herbicides, Fertilizer or Allowable Cut Effect 
for Genetics (No Herb.) 

8. Emphasis on Protection of Natural Values (Full 
Eco.) 

9. New Preferred Alternative (NPA) 

For each alternative, a sustained yield harvest level 
(allowable cut) has been calculated based on the 
combined timber production base (see Glossary) 
of the two SYUs. All allowable cut computations 
are made in cubic feet and converted to Scribner 
board feet equivalence for the first decade. There 
is no surplus inventory (see Glossary). Variables 
between alternatives include amounts of land 
allocated to timber production, types and amounts 
of intensive management practices and constraints 
on timber harvest to benefit other resource values. 
These relationships are displayed in Table 1-2. 
Treatments and design elements applicable to 
each alternative are discussed in the Forest 
Management Treatments and Design Elements 
section of this chapter. 

All harvest levels shown in Table 1-2 are computed 
on the respective combinations of intensive and 
constrained timber production bases. Table 1-3 
displays the breakdown by category and 
alternative. On areas allocated to constrained 
timber production (see Glossary), minimum 
harvest ages (MHA) vary to recognize specific 
needs for wildlife habitat diversity and visual 
resource management (VRM) considerations. The 
timber production base, for all alternatives except 
Alternative 5, excludes fragile site and 
reforestation problem withdrawals (approximately 
1 1 ,000 acres) and a minimum of 4,448 acres of 
commercial forest land withdrawn to protect 



Table 1-1 Land Jurisdiction in Acres 1 by County within Roseburg 
Sustained Yield Units 



13 



BLM 2 


U.S. Forest 
Service 


State 


Local Govt. 
& Private 


Total 


280 











280 


400 











400 


423,216 


978 


3,948 


1,032,150 


1,460,292 


423,896 3 


978 


3,948 


1,032,150 


1,460,972 



County 

Lane 
Jackson 
Douglas 
Totals 

' Acreage figures for BLM-administered lands are derived from master title plats. Other acreage figures are from Resource Atlases 
published by O.S.U. Extension Service, 1964. 

2 O&C lands make up 93 percent of the public lands administered by BLM. PD and CBWR lands comprise the remaining 4 and 3 percent, 
respectively. 

3 Refer to Appendix C, Table C-2. 



certain natural and cultural resources. Appendix C 
explains these withdrawals in more detail 
(Appendix C, Table C-2). 

Alternatives 2, 3, 4, 7 and 9 include modified area 
control (see Appendix C), which is a process for 
managing a given number of acres under a special 
timber harvest regime. In the Roseburg SYUs, 
52,047 acres are planned to be managed under the 
modified area control concept for Alternatives 3, 4 
and 7, 35,868 acres for Alternative 9 and 24,786 
acres for Alternative 2. These acres are primarily 
managed for riparian, spotted owl, old growth and 
visual values and are generally located within a 
corridor. This process would yield a timber harvest 
of approximately 4 MM bd. ft. in Alternative 2, 6 
MM bd. ft. in Alternative 9 and 9 MM bd. ft. in 
Alternatives 3, 4 and 7. Harvest methods would 
vary, ranging from clearcut to individual tree 
selection. 

Alternative 1 - Maximum 
Timber Production 

Timber production would be maximized while 
meeting legal requirements to protect federally 
listed threatened and endangered species and 
cultural resources. This alternative would allocate 
386,622 acres to intensive timber management and 
provide an annual timber sale program of 289 MM 
bd. ft. through accomplishment of various 
intensive timber management practices (see Table 
1-2). Lands not allocated to timber production 
(4,448 acres) would be managed for other 
resources such as cultural, established recreation 
sites and threatened and endangered species. 
Timber available for final harvest would have an 
average size of 12.7 inches dbh, normally reached 
in 40 years. Harvest at this size would occur during 
the 5th through 17th decades of the 400-year 
projection period. 



This alternative provides for harvest of stream 
buffers consistent with the Oregon Forest 
Practices Act; however, specific protection for 
riparian zones, wetlands and northern spotted 
owls would not be provided. 

Alternative 2 - Strong Emphasis 
on Timber Production 

Under this alternative, 360,580 acres of 
commercial forest land would be allocated to 
intensive timber management with an additional 
24,786 acres managed under modified area control 
(Appendix C). This would provide an annual 
timber sale program of 267 MM bd. ft. Stream 
buffers averaging 200 feet wide would be provided 
on third order or greater streams managed under 
modified area control. Approximately 5,700 acres 
of commercial forest land would be withdrawn 
from the allowable cut base to provide for other 
resource uses (Appendix C, Table C-2). Timber 
available for final harvest in the intensive timber 
base would have an average size of 14.4 inches 
dbh, normally reached in 50 years. Harvest at this 
size would occur from the 5th through 10th 
decades during the 400-year projection period. 

Alternative 3 - Lower Average 
Minimum Harvest Size 

Allocation of 333,319 acres of commercial 
forest land to intensive timber management would 
occur under this alternative. An additional 52,047 
acres, including an average 200-foot buffer on 
third order and greater streams and selected VRM 
lands and wildlife habitat, would be managed 
under modified area control (Table 1-3 and 
Appendix C, Table C-4). This would produce an 
average timber sale program of 256 MM bd. ft. 
annually. Approximately 5,700 acres of 
commercial forest land would be withdrawn from 
the allowable cut base to provide for other 
resource uses. 



14 



Table 1-2 Comparison 


of Alternatives by Treatment - First Decade 






Alt. 1 


Alt. 2 


Alt. 3 


Alt. 4 


Alt. 5 


Alt. 6 


Alt. 7 


Alt 8 


Alt. 9 




Max. 


Emp 


Lo 




No 




No 


Full 






Tbr. 


Tbr. 


MHS 


OPA 


Action 


HD 


Herb. 


Eco. 


NPA 


Intensive Timber 




















Production Base' (acres) 


386.622 


360.580 


333.319 


333.319 


377.098 


222.357 


261 191 





331.637 


Constrained Timber 




















Production Base' (acres) 





24.786 


52.047 


52.047 


13.886 


119.924 


52.047 


262,436 


35.868 


Annual Harvest 




















Total Million bd ft 


289 


267 


256 


249 


201 


183 


176 


84 


247 


Total Million cu It 


47 46 


4381 


4203 


41 00 


3303 


30 28 


28 94 


1383 


40 47 


Treatments 2 




















Transportation System (miles. acres) 


















New Construction ' 


928:5.568 


854,5.124 


822:4,932 


800;4,800 


616:3.696 


588.3,528 


551:3,306 


277, 1,662 


794.4.764 


Reconstruction 


641; 


590; 


568. 


552: 


425: 


406. 


381; 


191: 


548; 


Timber Harvest (acres) 




















Clearcut 


66.780 


61,411 


59.152 


57.548 


44.294 


42.298 


39,659 


19.915 


57.093 


Mortality Salvage 


4.138 


3,830 


3,325 


3,347 


21.949 


2.362 


2.646 





3.328 


Commercial Thinning 


3,889 


3.611 


3.479 


3.479 


7,357 


2.778 


2.802 





1.383 


Site Preparation (acres) 




















Broadcast Burning 




















(slash disposal) 


52,088 


47.901 


46.139 


44,887 


34.549 


32.992 


30,659 


15.534 


44.532 


Herbicide 


60.770 


55.884 


53,828 


52,369 


40,308 


38.491 





18.123 


51 955 


Manual 


2.003 


1,842 


1.775 


1.726 


1,329 


1.269 


23,790 


597 


1.713 


Mechanical 


4.675 


4.299 


4.141 


4.028 


3.101 


2,961 


2,776 


1.394 


3,997 


Planting (acres) 




















Initial plant' 


61,212 


56,287 


54.220 


52.748 


40,598 


38.770 


36.353 


18.253 


52.329 


Replant or Interplant 


18,364 


16.886 


16.266 


15,824 


12.179 


11.631 


10.906 


5.476 


15,698 


Plantation Protection (acres) 


36,061 


33,162 


31.942 


31,076 


23.919 


22.841 


21,416 


10.754 


30.830 


Plantation Maintenance and 


46,746 


42,988 


41.406 


40,284 


31.006 


29.609 


7,300 


13,940 


39.965 


Release- (acres) 




















Precommercial Thinning (acres) 


44.576 


42,240 


40.755 


40,755 


12.326 


31.370 


37.319 





40,449 


Fertilization (acres) 


61.270 


57.984 


56,029 


56,029 





43.659 








55,646 


1 See Glossary. 




















2 Each treatment is described in detail following description of the alternatives. 










1 Figured at the rate of 6 acres/mile of road includi 


ing landings. 














J Under all alternatives except Alternati 


ve 8, 15,200 acres would be planted 


with genet 


ically improved stock. 






5 All to be accomplished 


with herbicides except in 


Alternative 7 


where manual methods are to be 


employed 


exclusively. 





Table 1-3 Derivations of Timber Production Base Acreage 












Alternatives Including the Proposed Action 








Alt. 1 
Max. 
Tbr. 


Alt. 2 
Emp. 
Tbr. 


All. 3 

Lo 
MHS 


Alt. 4 
OPA 


Alt. 5 

No 
Action 


Alt. 6 
HD 


Alt. 7 

No 
Herb. 


Alt. 8 
Full 
Eco. 


Alt. 9 
NPA 


INTENSIVE TIMBER 
PRODUCTION BASE 


386,622 


360,580 


333.319 


333,319 


377,098 


222.357 


261,191 





331.637 


CONSTRAINED TIMBER 
PRODUCTION BASE 




















VRM (250 year modified 

area control) 
VRM (MHA-130) 
Wildlife (250 year 

modified area control) 
Wildlife (MHA-60) 
Wildlife (MHA-250) 
Wildlife (MHA-350) 












3.682 


21,104 






2,646 


49,401 






2,646 


49,401 


















31.345 



76,359 
12,220 


2,646 


49,401 








49.376 


107.180 
83.211 
22.669 


2.658 


33,210 






TOTAL CONSTRAINED 





24.786 


52.047 


52.047 


13.886 


119,924 


52.047 


262.436 


35.868 


TOTAL TIMBER 
PRODUCTION BASE' 


386.622 


385.366 


385.366 


385,366 


390,984 


342.281 


313,238 


262.436 


367.505 


' Refer to Land Use Allocati 


on. Append 


ix C, Table C-2 















15 



Timber stands available for final harvest in the 
intensive timber base would have an average size 
of 12.7 inches dbh, normally reached in 40 years. 
In actuality, harvest at this size would occur from 
the 5th through the 28th decades during the 400- 
year projection period. A regulated forest on 
intensive timber production lands would be 
reached in about the 30th decade. It is assumed 
that by the time a regulated forest is achieved, the 
annual harvest level from the lands allocated to 
timber production under this alternative and the 
Original Proposed Action (Alternative 4) could be 
increased to the highest level sustainable from this 
timber management base (estimated to be 
approximately 303 MM bd. ft.). 

Alternative 4 - The Original 
Proposed Action 

This alternative allocates the same acreages 
to timber and other resource management as 
Alternative 3. However, timber available for final 
harvest in the intensive timber base would have an 
average size of 14.4 inches dbh, normally reached 
in 50 years. This would produce an average annual 
timber sale program of 249 MM bd. ft. Harvest at 
this size would occur from the 4th through the 
10th decades during the 400-year projection 
period. A regulated forest on intensive timber 
production lands would be reached in about 13 
decades. Management elements would be identical 
to those in Alternative 3 (see Tables 1-2, 1-3 and 
Appendix C, Tables C-3, C-4). 

Alternative 5 - No Action 

Alternative 5 constitutes a continuation of 
the present allowable cut of 201 MM bd. ft. from 
390,984 acres allocated to timber production. 
Continuation of the same management practices, 
level of application and constraints used in the 
1972 allowable cut calculation is assumed. 
Management trends (such as reduced tractor 
yarding) established over the past decade would 
be continued. Minimal protection would be 
provided for some highly scenic areas, 
recreational sites and wildlife habitat. Non-timber 
allocations, limited to 400 acres, include buffers 
for recreation areas and sensitive visual corridors. 
Streamside buffers totaling 8,070 acres would be 
provided along third order and larger streams 
(Table C-4). Other land use allocations (Appendix 
C, Table C-2) and management objectives (Table 
1-2) proposed under this alternative are those 
incorporated in the 1972 Timber Management Plan 
for its second decade of application. 

Alternative 6 - Habitat Diversity 

Protection of some natural and cultural 
values, while accommodating timber production 
and other commodities, would be provided under 
Alternative 6. It would allocate 222,357 acres to 
intensive forest management with an additional 
119,924 acres managed under longer harvest 



cycles. The annual timber sale program would be 
183 MM bd. ft. Timber available for final harvest in 
the intensive timber base would have an average 
size of 14.4 inches dbh, normally reached in 50 
years. Stream buffers at least 250 feet wide would 
be provided on third order and greater streams. In 
addition, 48,790 acres of commercial forest land 
would be withdrawn from the allowable cut base to 
provide for other resource uses (Appendix C, 
Table C-2). 

Alternative 7 - No Herbicides, 
Fertilizer or Allowable Cut 
Effect for Genetics 

This alternative differs from Alternative 4 
in that the forest management treatments of 
herbicide and fertilizer applications would not be 
incorporated. Without the use of herbicides to 
control competing vegetation, approximately 
72,100 acres would be withdrawn from the timber 
production base due to reforestation problems. 
Control of vegetation for timber management by 
using biological, mechanical or manual means 
would be prescribed to approximately the same 
dollar level of investment as would be used for 
herbicide and fertilizer applications in Alternative 4 
to provide a means of comparison. 

Alternative 7 would provide for continued planting 
of genetically improved trees, but the allowable cut 
computation would not take credit for expected 
growth increases. This would produce an average 
annual timber sale program of 176 MM bd. ft. 
Timber available for final harvest in the intensive 
timber management base would have an average 
size of 13.6 inches dbh, normally reached in 50 
years. 

Alternative 8 - Emphasis on 
Protection of Natural Values 

In this alternative, protection would be 
provided for a variety of wildlife habitats, sensitive 
botanical species, visual resources, research 
natural areas, riparian areas and dispersed 
recreational activity areas. Unharvested stream 
buffers, varying in width by stream order from 150 
to 500 feet, would be provided on all streams. This 
is considered to be a full ecosystem alternative. 

No land would be included in the intensive timber 
base. Treatments not planned for Alternative 8 are 
mortality salvage, commercial and precommercial 
thinning, fertilization and genetically improved 
stock (Table 1-2). Approximately 262,436 acres of 
commercial forest land would be included in the 
constrained timber base (Table 1-3). Minimum 
harvest age varies from 60 years to 350 years. This 
would produce an average timber sale program of 
84 MM bd. ft. annually. Fifteen-year spacing 
between adjacent harvest areas would be 
employed. In addition, 128,634 acres of 



16 



commercial forest land would be withdrawn from 
the allowable cut base to protect non-timber 
resource values (Appendix C, Table C-2). Harvest 
from these areas would be allowed only when of 
direct benefit to the protected resources. 

Alternative 9 - New Preferred 
Alternative 



This alternative seeks a high level of 
timber production while managing for a variety of 
natural values and recreation opportunities. This 
alternative is similar to Alternative 4, except that 
18,332 acres of riparian area along third order and 
greater streams would be withdrawn from the 
allowable cut base. 



Under this alternative 331,637 acres of commercial 
forest land would be allocated to intensive timber 
management with an additional 35,868 acres 
managed under modified area control. This would 
produce an average annual timber sale program of 
247 MM bd. ft. Timber available for final harvest in 
the intensive base would have an average size of 
14.4 inches dbh, normally reached in 50 years. 
Harvest at this size would occur from the 4th 
through the 10th decades during the 400-year 
projection period. A regulated forest on intensive 
timber production lands would be reached in 
about 13 decades. An additional 5,233 acres of 
commercial forest land would be withdrawn from 
the allowable cut base to provide for cultural and 
botanical resources, bald eagles and recreation 
sites (Table C-2). 

Forest Management 
Treatments and Design 
Elements 



Table 1-2 displays, in typical sequence, the types 
and levels of treatments for each alternative. 
Following harvest by clearcut or single tree 
selection, these treatments are used to achieve 
prompt reforestation and to increase subsequent 
growth of commercial coniferous species. The 
following discussion of treatments will be in the 
same order as listed in Table 1-2. 

Not every treatment listed in Table 1-2 would be 
applied to every acre. A number of treatment 
combinations are possible and could be employed. 
The purpose of this section is to elaborate on what 
each treatment entails and quantify the magnitude 
of the actions. Treatments would be identified and 
scheduled through application of the recently 
adopted forest data system (Solutions to 
Operations and Reforestation Monitoring Systems- 
STORMS 1981). For those actions required in 



timber sale contracts, the final determination of 
treatment needs would be made during timber sale 
planning. 



Contracts, usually awarded on a competitive basis, 
are the means of accomplishing all timber harvest 
and many forest development practices. The 
standard and special provisions (which include 
mitigating measures) in a contract set forth the 
performance standards to be followed by the 
contractor in carrying out the action in accordance 
with applicable laws, regulations and policies. In 
contract preparation, selection of special 
provisions is governed by the scope of the action 
to be undertaken and the physical characteristics 
of the specific site. The standard provisions of the 
basic timber sale contract, Bureau Form 5450-3, 
are applicable for all timber sales. Limitations on 
timber harvesting and related activities, as 
identified in the Church Report (U.S. Congress, 
Senate 1973) and analyzed in the BLM Timber 
Management - Final EIS-1975, have been adopted 
by BLM. Bureau manuals and manual supplements 
provide a variety of approved special provisions for 
use, as appropriate, in individual contracts. The 
combination of selected special provisions 
constitutes Section 41 of the timber sale contract 
(Form 5450-3). 

Prior to any vegetative or ground manipulation, 
BLM requires a survey of the project site for plants 
and animals listed or proposed for listing/as 
threatened and endangered species. If a project 
might affect any federally listed or proposed 
threatened or endangered species or its critical 
habitat, every effort would be made to modify, 
relocate or abandon the project in order to obtain 
a no effect determination. If BLM determines that a 
project cannot be altered or abandoned, 
consultation with the U.S. Fish and Wildlife Service 
would be initiated (50 CFR 402; Endangered 
Species Act of 1973, as amended). 

Whenever evidence of historic or prehistoric 
occupation is identified during BLM activities, 
special surveys are undertaken to determine 
possible conflicts in management objectives. In 
addition, a Class III (complete) cultural resources 
inventory is required on all areas to be subjected 
to ground disturbing activities. This is 
accomplished in the pre-planning stage of a 
treatment and the results analyzed in the 
environmental assessment addressing the action 
(BLM Manual 8100, Cultural Resources 
Management). When a cultural resource is 
discovered during timber harvest or associated 
activities, operations in proximity are immediately 
suspended and may only resume upon receipt of 
written instructions from the authorized BLM 
officer. Procedures under 36 CFR 800 would then 
be followed, including consultation with the State 
Historic Preservation Officer in the determinations 
of eligibility and effects. 



17 



Transportation System 

Oregon Manual Supplement, Release 5-115 of 
April 10, 1975, would be used in preparing road 
construction requirements for timber sale 
contracts. Engineering terminology and types of 
construction equipment are defined in the manual 
supplement and specifications for all aspects of 
construction, reconstruction and surfacing are 
provided. 

Methods of slope protection are provided to avoid 
collapse of cut-and-fill embankments. 
Specifications for rock pits and quarries include 
provisions for minimum visual intrusion, drainage 
and control of runoff and restoration following 
use. 

Special stipulations are provided for the 
installation of stream crossing structures, such as 
corrugated metal culverts, so that fish passage is 
not impeded. These measures may include 
imposing gradient limitations for the structures 
and/or installing baffles to reduce water velocity 
through the culverts. 

One section of the manual supplement provides 
design features to control and minimize erosion 
during road construction and throughout the 
design life of the road. Another section addresses 
soil stabilization practices, including planting, 
seeding, mulching and fertilizing for establishment 
of soil-binding vegetation. 

Road reconstruction is proposed for all 
alternatives. The miles of road to be reconstructed 
range from 641 under Alternative 1 to 191 miles 
under Alternative 8 (Table 1-2). Similarly, the miles 
of new, permanent road to be constructed during 
the decade would range from 928 miles under 
Alternative 1 to 277 miles under Alternative 8 
(Table 1-2). Construction standards, i.e., stream 
crossing, subgrade width, ditch, cut-and-fill slope 
requirements, and type of surfacing, would be 
determined during the annual timber sale planning 
process. Basic construction operations as well as a 
brief history of transportation systems are 
described in detail in the programmatic 
environmental impact statement BLM prepared on 
timber management in the western United States 
(USDI, BLM 1975), hereafter referred to as the 
BLM Timber Management FEIS. 

Road closures are planned for all alternatives 
where significant impacts to wildlife are occurring 
or likely to occur as a result of uncontrolled 
vehicle access. 

Timber Harvest 

The primary timber harvest method to be 
employed during the next 10-year period would be 
clearcutting. An estimated 78 percent of the 
proposed final harvest by clearcutting (see Table 
1-2 for proposed acreages by alternatives) would 



be accomplished by high lead cable yarding 
systems. Another 9 percent would be 
accomplished by cable yarding systems 
specifically providing partial log suspension and 5 
percent providing full log suspension. The 
remaining 8 percent would be harvested by tractor 
skidding, of which 19 percent would be 
accomplished using "low ground pressure" 
equipment. This variety of logging systems is a 
design feature employed primarily for watershed 
protection and reduced soil damage. Refer to the 
BLM Timber Management FEIS for a detailed 
description of logging systems. 

Timber harvesting limitations pertaining 
specifically to clearcutting, as identified in the 
Church Report (U.S. Congress, Senate 1972), have 
been adopted by BLM. These limitations are 
incorporated in the Oregon Manual Supplement 
5424, which lists special provisions or stipulations 
for use in the logging requirements portion of a 
timber sale contract. 

Acreages allocated to the constrained timber base, 
including those managed under modified area 
control, would be harvested by individual tree 
selection, shelterwood and/or clearcutting 
methods. (Also, see discussion on Modified Area 
Control in Appendix C.) 

Single tree selection would be employed for 
harvest of dead and dying timber (mortality 
salvage) in stands not scheduled for harvest within 
the 10-year period. Mortality salvage would take 
place on lands in the intensive timber production 
base and on all other lands in the event of a major 
catastrophic event or when beneficial to wildlife or 
fish. The variance in acreages proposed for 
mortality salvage (Table 1-2) reflects the 
differences in over-mature timber available under 
each alternative. 

Commercial thinning would be applied to 
intensively managed timber stands between the 
ages of 30 and 60 years. The interval of treatment 
(ranging from 10 to 30 years) would vary 
according to site characterization with poor sites 
having longer intervals. Acreages proposed for 
commercial thinning by alternative are presented 
in Table 1-2. 



Site Preparation 



Site preparation procedures are used to 
prepare newly harvested and inadequately stocked 
areas for the planting of a new crop of trees. Four 
types of site preparation treatments (broadcast 
burning, herbicides, mechanical and manual) are 
planned within the SYUs for the proposal period 
(Table 1-2). 

The main site preparation treatment would be 
broadcast burning to control competing 
vegetation, provide planting site accessibility and 
reduce the fire hazard. Burning would occur at 



18 



times approved by the Oregon State Department 
of Forestry which administers the Smoke 
Management portion of the State's Air Quality 
Implementation Plan. Acreage requiring slash 
disposal by broadcast burning (Table 1-2) may 
receive one or more of the following site 
preparation treatments. 



Site preparation treatment using herbicides (Table 
1-4) is included in all alternatives except 
Alternative 7. Herbicides are used to increase 
plantation survival rate by control of grasses, 
forbs, brush and noncommercial tree species. 
These treatments improve the potential for 
success by reducing competition for light, 



Table 1-4 Estimated Ten-Year Use of Herbicides 














Chemical 


Method 


Season 


Carrier 


Target Species 


Application 

Rate 1 
(Ibs./Acre) 








Estimated Ac 


res 






Alt. 1 
Max. 
Tbr. 


Alt. 2 
Emp. 
Tbr. 


Alt. 3 

Lo 
MHS 


Alt. 4 
OPA 


Alt. 5 

No 
Action 


Alt. 6 Alt. 
HD 


7- Alt 8 
Full 
Eco. 


Alt. 9 
NPA 


SITE PREPARATION 


























Atrazine- 
Dowpon 


Aerial 


Spring 


Water 


Annual & Perennial grasses 


4 lbs ea 


33.302 


30.624 


29.498 


28.698 


22.089 


21.093 


9 931 


28 471 


Atrazine 
Dowpon- 
2.4D 


Aerial 


Spring 


Water 


Grasses, lorbs. brush 


•1 4 2 lbs 


4,315 


3.968 


3.822 


3,718 


2,862 


2.733 


1.287 


3.689 


Velpar 


Aerial 


Spring 


Water 


Grasses, torbs 


1 lb 


6.563 


6,036 


5.813 


5,656 


4,353 


4.157 


1.957 


5.611 


Velpar 


Aerial 


Spring 


Water 


Annual & Perennial grasses 
& forbs 


2 lbs 


3,525 


3,241 


3.122 


3,037 


2,338 


2.233 


1.051 


3,013 


Roundup 
(Glyphosate) 


Aerial 


Spring 


Water 


Annual & Perennial grasses 
& forbs 


1 qt (1 lb) 


425 


391 


377 


367 


282 


270 


127 


364 


Roundup 


Aerial 


Late 
Summer 


Water 


Deciduous brush & hardwoods 


1-1 2 qls 
(1-1/2 lb.) 


8.812 


8.103 


7.805 


7.593 


5.845 


5,581 


2,628 


7.533 


Garlon 4 


Aerial 


Early 
Summer 


Water 


Brush & other herbaceous 
vegetation 


4-8 lbs. 


912 


838 


807 


786 


605 


577 


272 


780 


Roundup 


Ground 
(back- 
pack) 


Spring 


Water 


Annual & Perennial grasses 


1% solution 
(1 Ib/ac. 
approx ) 


668 


615 


592 


576 


443 


423 


199 


571 


Roundup 


Ground 
(back- 
pack) 


Spring 


Water 


Annual & Perennial grasses 
& forbs 


2% solution 
(1 lb ac 
approx I 


2.248 


2.068 


1,992 


1.938 


1.491 


1.424 


671 


1,923 


PLANTATION 
MAINTENANCE & 
RELEASE 


























Atrazine- 
Dowpon 


Aerial 


Spring 


Water 


Annual & Perennial grasses 


4 lbs ea. 


12.154 


11 177 


10,766 


10,474 


8.062 


7,698 


3,624 


10.391 


Atrazine 
Dowpon-2.4-D 


Aerial 


Spring 


Water 


Annual & Perennial grasses, 
brush & hardwoods 


4/4/2 lbs. 


2.478 


2.278 


2.195 


2.135 


1.643 


1.569 


739 


2.118 


2.4-D 


Aerial 


Spring 


Water & 
Oil 


Evergreen brush & hardwood 
species, Herbaceous 
vegetation 


3 lbs 


3,973 


3,654 


3,520 


3.424 


2.636 


2.517 


1,185 


3.397 


Roundup 


Aerial 


Late 
Summer 


Water 


Deciduous brush & 
hardwoods 


1 1 2 qts 


12.949 


11.908 


1 1 .469 


11.158 


8.589 


8.202 


3.861 


11.070 


Velpar 


Aerial 


Spring 


Water 


Annual & Perennial grasses 
& forbs 


1-2 lbs 


5.282 


4.857 


4,679 


4.552 


3.504 


3.346 


1.575 


4.516 


Asulox 


Aerial 


Late 
Summer 


Water 


Bracken fern 


3,3 lbs 
(1 gal.) 


3.272 


3,009 


2.898 


2.820 


2,170 


2.073 


976 


2.798 


Garlon 4 


Aerial 


Spring 


Water & 
Oil 


Evergreen & deciduous 
brush & hardwoods 


1-2 lbs. 


3.319 


3.053 


2.939 


2861 


2,201 


2,102 


990 


2.838 


Garlon 4 


Ground 


All 
Seasons 


Diesel 


Bigleaf maple 
(Basal Spray) 


1% Solutton- 

1 gal 100 gal 

mix (4 Ibs./ac 

approx ) 




473 


456 


443 


341 


326 


153 


439 


Garlon 3A 


Hand 


All 
Seasons 


Dilute 

with 
water 

i 1 


Bigleaf maple. Madrone. 
Red alder (hack'squirt) 


1 ml Solution 
per inch dia 

approx .) 


1.075 


989 


952 


927 


713 


681 


321 


920 


Tordon 101 R 

(picloram- 

2.4-D) 


Hand 


Spring 


None un- 
diluted 


Madrone & other hardwoods 


1 ml. per Inch 
dia 
lb ac ) 




1.590 


1.532 


1.490 


1 147 


1.095 


516 


1 478 


' Active ingredients (in total pounds) applied may be figu 
alternative. 


red by mult 


iplying the application rate by the 


estimated acres under each 


* Alternative 7 does not em 


ploy the 


use of herbicides. 





















19 



moisture and soil nutrients during the tree 
seedling establishment period. Application and 
monitoring of herbicides would be in accordance 
with BLM's FEIS Vegetation Management with 
Herbicides: Western Oregon 1978 through 1987. 
See the following Plantation Maintenance and 
Release section for more detail. Alternative 7, 
which does not incorporate herbicide use, 
employs the manual method of paper mulching on 
slopes less than 65 percent. 

Manual site preparation would occur on some 
acreage during the next decade (Table 1-2). 
Treatments would consist of paper mulching, 
scalping or brush cutting and piling for burning. 

Mechanical site preparation would consist of 
scarification and piling or windrowing of slash, 
brush and unmerchantable stems. Bulldozers 
equipped with a brush blade would normally be 
used. However, this type of equipment would be 
restricted to areas with slopes less than 35 
percent, low soil moisture conditions and suitable 
soil types. 



Planting 



To achieve adequate reforestation within 
five years following harvest on timber production 
lands, harvested areas would be planted with 
commercial coniferous species (Douglas-fir, grand 
fir, incense cedar, Jeffrey pine and ponderosa 
pine) within one year of the completion of site 
preparation. Planting stock is nursery grown from 
seed collected on sites and at elevations similar to 
the specific project area. Genetically improved 
stock is also being nursery grown and would be 
scheduled for planting on 15,200 acres. The broad 
selection of parent trees for genetically improved 
stock is intended to maintain genetic diversity 
(BLM Instruction Memorandum OR 79-334). 

Reforestation experience in the Roseburg SYUs 
shows that target stocking levels of 245 to 320 
trees per acre, depending on site class, cannot 
always be achieved by the initial planting. Post- 
treatment surveys would be conducted to 
determine the rate of survival and when replanting 
or interplanting would be required to meet 
stocking standards. 

Plantation Protection 

Estimated acreages that would require some 
type of protective treatment are shown in Table 1- 
2. Treatments would include proteotion from the 
sun by shading and placing plastic tubing or 
netting over seedlings to protect them from 
damage by deer, elk, porcupine or other small 
animals. Porcupine would be trapped when they 
occur in significant numbers in a plantation. The 
total number of acres requiring each of these 
treatments would be determined in conjunction 
with normal reforestation surveys. 



Plantation Maintenance and 
Release 

Maintenance treatments promote the survival 
and establishment of coniferous seedlings. 
Release treatments reduce competition for light, 
moisture and nutrients between shrubs or grass 
and existing commercial coniferous seedlings and 
promote dominance and growth of established 
coniferous trees. 

In recent harvest areas, grass, forbs, shrubs and 
hardwoods often suppress the growth of conifer 
seedlings. The degree and type of competition 
varies with the individual site. On dry sites, grass, 
forbs and shrubs are strong competitors for water, 
while elsewhere hardwoods grow rapidly enough 
to shut out essential light and compete for water 
during the dry summer. With reduced competition, 
the conifers rapidly grow beyond the point where 
they can be overtopped and further suppressed by 
surrounding vegetation. When this growth 
situation is achieved (approximately 3 to 10 years 
from planting), there would be no further control 
of competing vegetation necessary. 

Each area proposed for maintenance or release 
treatment would undergo a site specific 
environmental assessment. During this analysis, 
alternative methods of vegetation control are 
considered, including chemical, manual and 
mechanical means. Assessments addressing 
specific herbicide projects are prepared and tiered 
under BLM's FEIS Vegetation Management with 
Herbicides: Western Oregon - 1978 through 1987. 

In recent years, herbicides have been used 
effectively to inhibit the growth of competing 
vegetation, thus increasing available water, 
nutrients and light for suppressed conifers. 
Herbicides are applied aerially or by several 
ground methods. The method selected is 
dependent on costs, topography, limits of the 
equipment, kind and dispersion of target plants, 
potential environmental impacts and biological 
conditions. Most herbicide applications in the 
Roseburg SYUs would be by helicopters equipped 
with positive shut-off spray systems to limit 
herbicide aplication to the target areas. Helicopter 
application would be accomplished under contract 
through the competitive bidding process. 

Timing of herbicide treatment is stringently 
controlled in relation to specified weather 
conditions such as temperature, humidity and 
wind. There is full authority for ordering cessation 
of operations based on adverse field conditions. 
Both equipment and operators are frequently 
checked by field project supervisors. Only 
registered chemicals would be used and in 
accordance with labeled instructions on the 
container. Handling, storage and application of 
chemicals would be in accordance with the 



20 



Oregon Forest Practices Act (see the 
Interrelationships section, State and Local 
Government). 

Protective stream buffers (determined according 
to stream classification and herbicide used) and 
monitoring of herbicide application are as 
described in the FEIS mentioned above. 
Continuous administration of spraying contracts in 
progress is required. Water samples of selected 
streams would be taken prior to spraying to 
establish baseline quality and at specified intervals 
thereafter. 

The use of herbicides for plantation maintenance 
and release is included in all alternatives except 
for Alternative 7 (Table 1-2). Table 1-4 shows the 
chemicals, target species and estimated acreage of 
herbicide use as proposed during the 10-year 
period. 

Precommercial Thinning 

Under all alternatives except Alternative 8, 
precommercial thinning would be applied to 
timber stands between 10 and 20 years of age 
which contain over 500 stems per acre (estimated 
to be 60 percent of the stands). This treatment 
concentrates available nutrients, moisture and 
light into those trees which would be the eventual 
crop for future harvest. 

The number of trees cut per acre during 
precommercial thinning is dependent on the 
density of the stand before thinning. While average 
spacing is approximately 12 feet, the number of 
crop trees left may vary between 245 and 320 per 
acre. Contract specifications, emphasized by field 
instructions to crews, cover desired spacing of 
crop trees and criteria for crop tree selection. 

Fertilization 

Areas precommercially and commercially 
thinned and portions of areas where stocking 
control was achieved through plantation spacing 
would be fertilized (Table 1-2) except in 
Alternatives 5, 7 and 8. Continuing studies and 
analysis will be conducted to determine fertilizer 
response and economic effectiveness of planned 
projects. The average application is expected to be 
200 pounds of nitrogen per acre. Stands would be 
fertilized when precommercially thinned, 
commercially thinned and at 10-year intervals 
thereafter until 10 years before final harvest. In 
addition to acceleration of growth for up to seven 
years following treatment, fertilization reduces 
shock associated with thinning. 

Comparison of Impacts 

This section compares in tabular form (Table 
1-5) the impacts of each alternative, including the 
New Preferred Alternative (Alt. 9) and the Original 
Proposed Action (Alt. 4). While impacts have been 



described in detail in Chapter 3, Table 1-5 is 
presented to assist decisionmakers and reviewers 
by summarizing the impacts of each alternative, 
thereby permitting major issues to be defined and 
analyzed. 

Two areas of major impacts are wildlife habitat and 
economic conditions. The greatest total habitat 
modification would occur in Alternative 1. The 
greatest old growth habitat modification would 
occur in Alternative 5, where about 70 percent of 
old growth habitat would be removed by the end of 
the first decade. Alternative 8 would result in an 
increase of old growth habitat over the long term; 
all other alternatives would result in long-term 
decreases of old growth habitat. 

Alternative 1 would be most beneficial to the 
economic situation, providing about 1,500 more 
jobs than would be provided by continuation of the 
existing program. Alternative 8 would have the 
greatest adverse impact, providing approximately 
2,000 fewer jobs than would a continuation of the 
existing program (Alternative 5). 



Other areas of impact are soil erosion and 
sediment yield. Alternative 1 would cause the most 
erosion; Alternative 8 the least. Cumulative 
sediments produced as a result of timber 
management activities would increase from levels 
in the past decade by 26 percent in Alternative 1 
and decrease by 100 percent in Alternative 8 where 
no new sedimentation is expected. Alternative 8 
would have the least adverse impacts attributable 
to either soil erosion or sediment yield. 



Implementation 
Final Decision 



After release of the final EIS (and 
following the comment period) the District 
Manager will review the public comments on both 
draft and final EISs and prepare a Record of 
Decision. The recommended decision may be to 
select one of the EIS alternatives intact, or to blend 
features from several alternatives that fall within 
the range of actions analyzed in the EIS. The final 
decision will be made by the State Director. 
Significant conflicts, alternatives, environmental 
preferences and economic and technical 
considerations will be addressed in the Record of 
Decision, which is expected later in 1983. 

Monitoring and Studies 

BLM land management programs are monitored 
in various ways. Currently, forest management 
practices are monitored primarily through 
administration of the contracts under which most 
actions are authorized. Timber sale contracts are 
inspected at least once a week, when active, and 
more often if sensitive operations are in progress. 



21 



Table 1-5 Si 

Environmental Components 


immary 

Units of 


of In 

Existing 


npac 

All. 1 


Is 

Alt. 2 


Alt. 3 


Alt. 4 


Alt. 5 


Alt. 6 


All 7 


Alt. 8 


Alt. 9 




Impacted 


Measure 


Situation 


Max. Tbr. 


Emp. Tbr. 


Lo MHS 


OPA 


No 
Action 


HD 


No Herb. 


Full Eco. 


NPA 


Remarks 


Air Quality 


























Nitrous oxides 


tons/year 




365 


335 


323 


314 


242 


231 


217 


109 


312 




Hydrocarbons 


tons year 


NA 


2,279 


2,096 


2,019 


1.964 


1.512 


1,443 


1,353 


680 


1.948 




Particulates 


tons/year 




3.828 


3,521 


3,391 


3.299 


2,539 


2,425 


2.274 


1,142 


3.273 




Soils 


























Lost productivity 


acres/decade 


NA 


3.568 


3,283 


3.150 


3.072 


3.143 


2.260 


2,141 


985 


3.071 


+es roads. 


Water Resources 


























Sediment yield 


tons x 100/ 


























decade 


NA 


4,915 


3,151 


2,813 


2.728 


2.772 


993 


1.883 


429 


1.235 




Vegetation 


























Acres denuded 


























Road construction 


acres, decade 


3,553 


5,568 


5.124 


4.932 


4.800 


3.696 


3.528 


3.306 


1.662 


4.764 




Plant habitat altered by 


























Herbicide use 


acres-'decade 


41,231 


107,516 


98,872 


95,234 


92.653 


71,314 


68,100 





32.063 


91.920 




Timber harvesting 


acres/decade 


75.004 


74.807 


68,852 


65.956 


64.374 


73,600 


47,438 


45.107 


19,915 


61,804 




Wildlife Habitat 


























Habitat modified 


acres decade 


NA 


125.000 


116.200 


111,600 


109.900 


89.600 


82,300 


85.700 


21.600 


107.000 


Roads, harvest and thinning. 


Early successional 


acres 


75.000 


97.400 


92.000 


89,700 


88.100 


71.800 


73,300 


71.000 


51.600 


87 800 


Habitat < 15 years old 


stage habitat, end 


























1st decade 


























Early successional 


acres 


75,000 


134.000 


74.300 


119,500 


71,700 


72,600 


51.000 


71.100 


37,400 


100,500 


Habitat 15 years old 


stage habitat, end 


























10th decade 


























Old growth habitat, 


acres 


110,900 


66.500 


70,600 


72.400 


73.600 


35,000 


85.800 


87.600 


103,200 


74,400 


Habitat 196 years and older. 


end 1st decade 


























Old growth habitat. 


acres 


110,900 


13.700 


21.100 


31,800 


31,800 


7,300 


68.100 


70,000 


123.500 


38.900 


Habitat 196 years and older 


end 10th decade 


























Wildlife Population 


























Roosevelt Elk, end 


Percent change 


NA 


-25% 


-25% 


-25% 


-25% 


-10% 


-5% 


-20% 


No 


-25% 


Plus or minus 5 percent. 


of 5th decade, 


from existing 


















Change 






Tyee Area only 


























Roosevelt Elk, end 


Percent change 


NA 


-25% 


-25% 


-30% 


-20% 


-20% 


-5% 


-20% 


No 


-20% 


Plus or minus 5 percent 


of 10th decade, 


from existing 


















Change 






Tyee Area only 


























N. Spotted Owl, end 


Pairs 


55 








18 


18 





25 


18 


55 


19 


300 acre old growth 


of 10th decade 
























management recommendation 


N Spotted Owl, end 


Pairs 


55 

















24 





42 





1 .000 acre old growth 


of 10th decade 
























management recommendation 


Snag Dependent Wildlife 


Percent of 
Potential 


60% 


• 10% 


10% 


20-30% 


20-30% 


10% 


40-50% 


40-50% 


70-80% 


20-30% 


Long term 


Recreation 


Ability to 
meet needs 


- 


-L 


♦ L 


♦ L 


♦L 


-M 


+ L 


+ L 


♦L 


+ L 




Cultural Resources 


Inadvertent 
degradation 
(undiscovered 
sites) 




-H 


-H 


-M 


-L 


-L 


-L 


-L 


-L 


-L 


Based on comparison of 
harvest levels 


Visual Resources 


Degradation of 
scenic quality 




-H 


-M 


-M 


-M 


-H 


-L 


-L 





-M 




Areas of Critical 


Degradation of 


_ 


-M 











-H 
















Enviromental Concern 


resource 
values 
























Special Areas 


Site 
degradation 


- 


•H 


-L 


-L 


-L 


-H 


-L 


-L 


-L 


-L 




Energy Use 


Billion Btu's 

consumed 

annually 


~~ 


834 


770 


741 


723 


528 


536 


514 


218 


716 




Socioeconomic ' 


























Impacts Compared to 


























Existing Condition 


























Total earnings 


$ millions 


39 2 


♦21 2 


•166 


• 14 3 


+ 129 


•28 


•09 


-2 4 


-21.6 


♦124 




Total employment 


jobs 


3,225 


"1,746 


♦1,367 


+ 1,178 


+ 1.058 


♦ 232 


-77 


-198 


-1.780 


+ 1.023 




Public revenue 


$ millions 


14 2 


-1 1 


-2.1 


-2 6 


-2 9 


-5 1 


-5.9 


-62 


-10.4 


-3 


Based on stumpage at 
S94/M bd ft 




S millions 


142 


♦22 


•193 


♦17.9 


• 170 


• 110 


•87 


-7 9 


-3.7 


♦ 168 


Based on stumpage at 
S260/Mbd ft 


Impacts Compared to No 


























Action Condition 


























Total earnings 


S millions 


42 


+ 184 


•138 


♦11 5 


•100 




-38 


-52 


-24.5 


♦9 6 




Total employment 


jobs 


3 457 


•1.514 


♦1,135 


•946 


♦826 




-310 


-430 


-2,012 


+ 791 




Public revenue 


S millions 


15.2 


-2 1 


-3 1 


-3 6 


-3 9 




-69 


-72 


-11 4 


-4 


Based on stumpage at 
S94.'Mbd ft 




$ millions 


15.2 


•21 


•183 


♦169 


♦160 




♦ 7 7 


+6 9 


-4.7 


+ 158 


Based on stumpage at 
S260 M bd ft 


' See Chapter 3 for discussion of d 


ual impact measures. 




r- Beneficial 


- Negative 


L Low 


M Medium H High 


2 Impacts measured f 


rom No Action Condition (Alternative 5). 


























1 


^JA - Not Applicable 











22 



Daily administrative visits are not uncommon when 
harvest is moving at a fast pace, slash disposal is 
occurring, or road construction involving critical 
aspects (such as stream crossing structures) is 
taking place. Service contracts, i.e., tree planting, 
precommercial thinning, tubing, manual brush 
cutting and fertilization, are monitored at regular 
intervals to determine the quality and quantity of 
completed work. Visits to these operations range 
from twice a week to the full-time presence of a 
Bureau contract administrator, depending on the 
experience of the contractor and rate of progress. 
Daily visits usually occur when there is reason to 
believe that the operator will require help in the 
interpretation of contract requirements. 

Silvicultural treatment success is monitored 
through a series of inventories and surveys 
performed at various times during the stand's life. 
Appropriate stocking surveys are performed both 
prior to and after a treatment is accomplished. 
Information from these surveys identifies the need 
for or success of a particular silvicultural 
treatment. This information is documented and 
maintained in the operations and reforestation 
records systems. 

Water quality monitoring would be carried out in 
accordance with Executive Orders 11514 (partially 
amended by 1 1 991 ) and 1 2088, Sections 208 and 
313 of the Clean Water Act (PL 95-217, PL 92-500 
as amended), BLM Manual 7240 and Oregon 
Department of Environmental Quality 
Memorandum of Understanding (MOU-OR 158). 
Standard analytical methods would be followed. 

Monitoring systems for other resource 
management programs (wildlife habitat, visual, 
cultural and recreational) outlined in the final 
decision would be developed and implemented. 

Requirements for Further 
Environmental Analysis 

This environmental impact statement may best 
be described as a regional statement for the 
proposed 10-year timber management plan and is 
considered applicable for the decade. Site specific 
environmental analysis and documentation 
(including categorical exclusion where 
appropriate) will be accomplished for each type of 
treatment under consideration. Interdisciplinary 
impact analysis will be tiered within the framework 
of this and other applicable environmental impact 
statements. 

An environmental assessment of a timber sale (or 
group of sales) will address the effects of the 
harvest method, yarding system, road construction 
or reconstruction, slash disposal and any other 
treatments conducted under the terms of a timber 
sale contract. Environmental analysis of forest 
development projects such as precommercial 
thinning, animal damage control, fertilization and 
herbicide applications will also be accomplished. 



With problems and conflicts identified through 
analysis, it is possible to design the proposed 
project in an environmentally sensible manner. 
Where the action is to be accomplished by a 
contractor, the environmental assessment is a 
primary means for determining appropriate 
contract stipulations. Projects to be accomplished 
by BLM personnel are conducted in accordance 
with the findings of the analysis and decision 
documents. 

If an environmental assessment indicates potential 
for significant impacts not already described in an 
existing EIS, an environmental impact statement or 
a supplement to an existing EIS may be required. 

Interrelationships 

Much of western Oregon is timber producing 
land. In addition to the BLM, jurisdictions include 
the U.S. Forest Service, State of Oregon, the 
counties, and private companies and individuals. 
Each entity approaches management of timber 
lands differently, although some periodically 
prepare internal or public plans for their 
management. 



Federal Agencies 



The Roseburg SYUs share in part a common 
boundary with the Umpqua National Forest. 
Coordination between the BLM District Manager 
and the Forest Supervisor is routine. Specific 
project and program coordination takes place as 
needed between all management levels of each 
agency and also between resource specialists. A 
cooperative agreement provides for interagency 
road construction and use and fire protection. 

The U.S. Army Corps of Engineers has the 
authority, under Section 404 of the Clean Water 
Act of 1977 (P.L. 95-217), to regulate the discharge 
of dredged or fill materials into any estuary, 
wetland or streams of the United States with flow 
in excess of five cubic feet per second. Normal 
silvicultural practices are exempt from this 
regulation. Based on the adequacy of BLM 
environmental protection practices, the Corps has 
issued BLM a general permit for all such activities. 
Under the permit, BLM provides the Corps, the 
State Division of Lands and certain environmental 
review agencies with advance notice of specific 
proposed projects. Larger projects exceeding 
limits in the general permit require a separate 
permit. 

The U.S. Fish and Wildlife Service administers the 
Endangered Species Act of 1973 (as amended). 
Accordingly, BLM consults with that agency when 
it is determined that a threatened or endangered 
species or its critical habitat may be affected. The 
purpose of consultation is to obtain expert advice 
on the appropriate course of action. The outcome 
of such consultation may mean modification or 
abandonment of the action. 



23 



The National Marine Fisheries Service (NMFS) is 
responsible for oversight and evaluation of 
activities which may affect marine, estuarine, and 
anadromous fishery resources. NMFS participates 
in comprehensive land and water use planning 
under the terms of the Water Resources Planning 
Act, the Coastal Zone Management Act, and the 
National Environmental Policy Act and makes 
recommendations for maintenance or 
enhancement of anadromous fishery resources 
under the terms of the Fish and Wildlife 
Coordination Act. 

The Soil Conservation Service (SCS) is 
responsible for all aspects of the National 
Cooperative Soil Survey. Accordingly, BLM has a 
cooperative agreement with SCS that provides for 
the development and utilization of soil surveys on 
lands that are of interest to the Bureau. The soil 
survey data will provide a basis for efficient 
interpretations for the Bureau planning and 
management systems. 

The National Park Service (NPS) administers the 
Nationwide Rivers Inventory, as provided under 
the National Wild and Scenic Rivers Act of 1968. 
Present efforts are directed toward inventory and 
evaluation to determine which free-flowing rivers 
and river segments are suitable for possible 
designation as components of the National Wild 
and Scenic Rivers System. BLM consultation with 
NPS is required if proposed management actions 
could alter a river's ability to meet established Wild 
and Scenic Rivers Act eligibility and/or 
classification criteria. 

State and Local Governments 

Section 202(c) of the Federal Land Policy 
and Management Act requires BLM to coordinate 
its planning efforts with those of State and local 
governments; assist in resolving inconsistencies in 
our mutual planning efforts; provide for State and 
local governmental involvement in development of 
BLM land use programs, regulations and land use 
decisions; and develop BLM resource 
management plans and programs consistent with 
those of State and local government to the extent 
that such BLM plans and programs are also 
consistent with Federal law and regulations. BLM 
coordination efforts involve a number of State and 
local administrative and planning agencies as 
highlighted below. 

The Intergovernmental Relations Division for the 
State of Oregon is the clearinghouse for the 
various State agencies. Notice of all BLM planning 
and major proposed actions are provided for 
coordinated State level review by the State 
Clearinghouse. The Regional Councils of 
Government serve as the clearinghouse for 
coordinated review of proposed BLM activities by 
county and local governments in their respective 
areas of interest. BLM involvement with the three 
counties in the SYUs is largely via the boards of 



county commissioners. Through these bodies, 
county governments participate in planning for 
land use, road construction and recreational 
developments on public lands administered by 
BLM. 

The Oregon Land Conservation and Development 
Commission (LCDC) administers the state 
comprehensive land use planning program as 
provided in Oregon State Statutes, Chapter 197 
(ORS 197). In this program, county and local 
governments are required to develop 
comprehensive land use plans and implementing 
ordinances consistent with 14 statewide planning 
goals and guidelines. These call for a balance 
between conservation and development to best 
meet public needs. 

Close relations have been established with LCDC 
to ensure cooperation and coordination of BLM 
programs and planning efforts with those 
conducted by county and local governments under 
ORS 197. The relationship of the Roseburg 
alternatives to the LCDC Statewide Goals is shown 
on Table 1-6. Discussion comments on this table 
generally focus attention on deficiencies in 
addressing the listed goals. 

Throughout the planning process, BLM has 
worked with Douglas County to achieve 
consistency with local plans. Methods of involving 
local governments have included: (1) frequent 
informal contacts to discuss local planning 
concerns; (2) invitations to participate in public 
tours, workshops and meetings; and (3) 
discussions with the Douglas County Planning 
Department to determine consistency of BLM's 
preferred land use plan with acknowledged local 
plans. 

The Comprehensive Land Use Plan for Douglas 
County was adopted by the Douglas County Board 
of Commissioners in 1981 and was recently 
accepted by LCDC. To meet the decision factor 
regarding consistency with State and local land 
use plans, the Original Proposed Action and New 
Preferred Alternative were developed to be 
consistent with the recently adopted 
Comprehensive Land Use Plan of Douglas County. 



24 



Table 1-6 Relationship of Roseburg EIS Alternatives to LCDC Statewide Goals 1 

LCDC Statewide Goal 

Number and Description Discussion 2 

1. To insure citizen involvement in all BLM land use planning process provides for public 

phases of the planning process. input at every stage — from assistance in the initial 

inventory to the identification of management 
opportunities, the development of alternatives, the 
environmental analysis and the final decision. 



2. To establish a land use process and 
policy framework as a basis for all 
decisions and actions. 



4. To conserve forest lands for forest 
uses. 



5. To conserve open space and protect 
natural and scenic resources. 



6. To maintain and improve the quality of 
the air, water and land resources. 



7. To protect life and property from natural 
disasters and hazards. 



8. To satisfy the recreational needs of the 
citizens of the State and visitors. 



9. To diversify and improve the economy of 
the State. 



12. To provide and encourage a safe, 
convenient and economic transportation 
system. 

13. To conserve energy 



All alternatives have been developed in accordance with 
the land use planning process authorized by the 
Federal Land Policy and Management Act of 1976 
which provides a policy framework for all decisions and 
actions. 

The planning area is predominately forest land. All 
alternatives provide retention of inventoried forest lands 
for forest users. No alternative exceeds the productive 
capacity of the land base and all proposed uses are 
compatible with forest uses. 

All alternatives conserve open space and protect 
mineral and cultural resources and T&E species. All 
alternatives except 1 protect scenic resources, wildlife 
habitat, natural areas and riparian areas to some 
degree. 

Only Alternative 1 does not fully address necessary 
enhancement of land and water quality for multiple use 
of forest lands or for meeting Federal and State 
minimum water quality standards. Slash burning will 
increase smoke (see Table 3-1). All alternatives would 
comply with the statewide smoke management plan. 

All alternatives include identification of potential hazard 
areas and general BLM program and operational 
measures for protection of life and property from 
natural disasters and hazards. 

Alternative 1 emphasizes those activities having 
minimal impact on the commercial timber base. 
Alternatives 2, 3, 4, 7 and 9 provide a variety of 
developed and dispersed recreation opportunities to 
meet most recreational needs. Alternatives 6 and 8 
provide for dispersed activities, natural areas and 
developed sites in some areas. Alternative 5 would 
continue the existing situation. Alternatives 1 and 5 
would fail to adequately meet some increasing needs 
for areas and facilities. 

Alternatives 1 and 2 would increase timber production, 
but lack diversity in that limited allocations would be 
provided for non-timber values. Alternatives 3, 4 and 9 
provide diversity and increase total economic returns. 
Alternative 5 maintains status quo while Alternatives 6, 
7 and 8 provide diversity but result in decreases in total 
economic returns. 

The forest transportation system will be expanded and 
improved. 



Conservation and efficient use of energy resources are 
objectives in all BLM activities. 

1 LCDC goals not generally applicable to the proposal and alternatives are: 3. Agricultural lands: 10. Housing; 1 1 . Public Facilities and Services: 
14. Urbanization; 15 Willamette Greenway: All Coastal Zone Goals 

' See Chapter 3 and Table 1-5 for impacts of the alternatives on the various resources. Also see the Index and Table of Contents for specific page 
numbers to specific resources. 



25 



The Oregon State Forester, by means of the Forest 
Practices Act of 1972, regulates timber harvest 
methods and supportive practices on all non- 
federal lands within the SYUs. Minimum standards 
are prescribed relating to the following forest 
practices: 

• Timber harvesting. 

• Reforestation of economically suitable lands. 

• Road construction and maintenance on forest 
land. 

• Chemical applications. 

• Slash disposal. 

• Maintenance of streamside buffers. 

Although Federal agencies are not bound by State 
forest practice rules, Bureau minimum standards 
meet or exceed State rules. The BLM and USFS, 
acting jointly, have entered into a Memorandum of 
Understanding (MOU) with the State Forester in 
this regard. 

BLM is a cooperator in the Statewide Smoke 
Management Plan administered by the Oregon 
State Forester in order to comply with the Clean 
Air Act of 1963 (as amended). The primary 
objective of the plan is to keep smoke from slash 
disposal operations away from population centers. 
Slash burning is allowed to begin only when 
smoke dispersion conditions are determined by 



Oregon State Department of Forestry (OSDF) to 
be favorable. 

OSDF is the primary contractor for fire protection 
of public lands administered by BLM in the SYUs. 
That department undertakes presuppression and 
suppression actions for all lands in the area. 

The Forestry Program for Oregon (Oregon State 
Board of Forestry 1977) outlines basic objectives 
of the Oregon State Board of Forestry for timber 
land management within the State. The 
relationship of the nine alternatives to these basic 
objectives is shown in Table 1-7. For the decade 
beginning in 1980, BLM harvest projections to 
meet Forestry Program for Oregon targets is 245.4 
MM bd. ft. annually. 

Management of wildlife, including fish, within the 
SYUs is the responsibility of the Oregon 
Department of Fish and Wildlife. The Sikes Act (PL 
93-452) as amended is the primary tool guiding 
coordination between BLM and ODFW. BLM, in 
managing lands under its jurisdiction, considers 
wildlife habitat as a resource category. A master 
Memorandum of Understanding with supplemental 
cooperative agreements describes the mutual 
responsibilities of the two agencies. Oregon 
Revised Statue 496.012 established goals for the 
management of the State's wildlife. The 



Table 1-7 Consistency of the Roseburg Alternatives with the Basic 
Objectives of the Forestry Program for Oregon 1 



ALTERNATIVES 



Basic Objective 



Consistent 



Minimally 
Consistent 



To maintain the maximum 
potential commercial 
forest land base 
consistent with other 
resource uses while 
assuring environmental 
quality 



To maintain or increase 
the allowable annual 
harvest level to its 
fullest potential to 
offset potential 
socio-economic impacts. 



To identify and implement 
the levels of intensive 
forest management required 
to achieve maximum growth 
and harvest 



To maintain community 
stability by remaining 
flexible for increases in 
future harvest levels that 
would offset proiected 
shortages 



Inconsistent 



2.3,4,6.7.8. 
9 



1 .2,3.4,5,9 



6.7.8 



1.2.3,4,6.9 



1.2,3,4,9 



5,6,7.8 



Discussion 

The benchmark (391.070 acres) for consistency 
is the commercial forest land base minus 
withdrawn TPCC lands Environmental quality 
would be protected to the degree specified in 
the Oregon Forest Practices Act. However. 
Alternative 1 would not meet management 
guidelines for certain lands as mandated by 
Congressional Acts and Federal Executive 
Orders (see Purpose and Need Section) because 
of impacts on riparian zones. 

The benchmark for consistency is the current 
allowable cut volume of 201 MM bd. ft. per 
year The level of cutting the land base can 
sustain is dependent on number of acres 
allocated to timber production, level of 
management the land base receives and 
productivity of the land 

BLM currently implements a full range of 
intensive timber management practices (refer 
to Forest Management Treatments and Design 
Elements, this chapter) for optimization of 
timber production. New and improved practices 
would be implemented consistent with 
technological advances 

The benchmark for consistency is the Roseburg 
District cooperative harvest target of 245 MM 
bd ft.. Yr.' as determined by OSDF 



1 Arrived at through consultation with Oregon State Department of Forestry. 

2 Oregon State Forestry Department, 1980. 



26 



consistency of the EIS alternatives with these 
goals is shown in Table 1-8. 

The Oregon Department of Environmental Quality 
(ODEQ) has lead responsibility for statewide water 
quality management planning in accordance with 
Section 208 of P.L. 92-500 (Federal Water Pollution 
Control Act) as amended by P.L. 95-217 (Clean 
Water Act). BLM and ODEQ have entered into a 
Memorandum of Understanding which outlines 
their respective roles in meeting State water 
quality objectives. The MOU assures close 
interagency cooperation, development and 
implementation of appropriate practices and 
control measures to comply with the Clean Water 
Act, and compliance with State requirements. BLM 
forest management practices meet or exceed 
objectives of the statewide water quality 
management plan. 



The cities of Canyonville, Drain and Riddle have 
signed Memoranda of Understanding with the 
BLM Roseburg District. These MOUs identify 
lands within municipal watershed boundaries and 
describe practices to be incorporated during 
timber management activities to maintain water 
quality. There are additional MOUs with a variety 
of agencies addressing resources within the 
Roseburg District. 



Table 1 -8 Consistency of the Alternatives with State of Oregon Wildlife Goals 




Minimally 




Goal 


Consistent Consistent Inconsistent 


Discussion 


To maintain all species of 


1-9' 


In the short term all alternatives would provide 


wildlife at optimum levels 




habitat sufficient to retain a representative 


and prevent the serious 


8 } 6 1-5. 7 and 9 


ecosystem and "prevent the serious depletion of 


depletion of any 




any indigenous species" Only Alternative 8 would 


indigenous species 




fully provide optimum long-term levels, although 
Alternative 6 would provide habitat at minimum 
viable levels for all species in the long term. 


To develop and manage the 


1-9' 


In the short term habitat diversity would 


lands and waters of the 




increase such that production and public 


State in a manner that 


6, 8 ? 2. 3, 4. 7 1 and 5 


enjoyment of wildlife would be enhanced by all 


will enhance the 


and 9 


alternatives In the long term Alternatives 6 and 


production and public 




8 would provide for all species, while 


enjoyment of wildlife 




Alternatives 2, 3, 4. 7 and 9 provide for 
enhancement and enjoyment of wildlife, but not 
for all species and at levels below optimum. 
Alternatives 1 and 5 would only enhance early 
serai stage species in the long term 


To develop and maintain 


1 -9.- 


All alternatives provide for public access 


public access to the lands 




through an extensive road network over both the 


and waters of the State 




short and long term. 


and the wildlife resources 






thereon. 






' Short-term (First decade) 






2 Long-term (Beyond first decade) 





27 



Chapter 2 Affected 
Environment 






m _i 




This chapter addresses the environment as it 
exists today within the Roseburg Sustained Yield 
Units (SYUs). In the SYUs there are approximately 
424,000 acres of BLM managed lands, of which 
404,000 acres are forested. On approximately 
169,000 acres (40 percent), timber harvest has 
occurred for several decades, and the environment 
described exhibits the effects of human use. On 
about 255,000 acres (60 percent), there has been 
no past timber management, although 
interspersed non-public lands have been managed 
for timber. Within this area there are approximately 
111,000 acres of 200-year-plus old growth on 
scattered tracts of public land. 

Chapter 2 provides a basis on which impacts of all 
the alternatives may be assessed. Data and 
analysis will be commensurate with the 
importance of the impact, with less important 
material summarized, consolidated or simply 
referenced. 

In preparation of this chapter, the primary data 
sources are documents of the Bureau planning 
system developed by the Roseburg District. The 
Unit Resource Analysis (URA), Planning Area 
Analysis (PAA) and proposed Management 
Framework Plan (MFP) for the Roseburg area are 
available for review at the Roseburg District Office 
of BLM in Roseburg, Oregon. 



28 



Other references supplementary to or updating 
planning system data are cited within the body of 
the text by author and date of publication. A listing 
of these references appears in the References 
Cited. 

Climate and Air Quality 

The area has a temperate marine climate with 
warm summers and mild, wet winters. In 
Roseburg, the mean maximum temperature is 
84° F, the mean minimum is 33° F. The record 
high was 109° F in 1946 and the record low was 
-6° in 1888. During summer days, soil 
temperatures have been found to exceed 160° F. 
Monthly precipitation, mostly as rain, ranges from 
5.46 inches in Riddle and 8.89 inches in Reston 
during January to less than 0.3 inches during July. 
Average precipitation is about 45 inches annually 
in the Roseburg SYUs. The maximum recorded 
was 60 inches at Twelvemile Creek. Snow may 
block roads in some winters, but snow is generally 
short-lived. 

Air movement patterns are predominately from the 
north (U.S. Department of Commerce, Weather 
Bureau, Cited in USDI, BLM 1980a), except during 
the late fall and early winter months (November, 
December, January), when winds are southerly. 
Mean yearly wind speeds in Roseburg are 4.5 
miles per hour. 

During the late summer and fall months, the 
valleys and interior hills of Douglas County are 
subject to frequent night-time inversions—cool air 
stabilizing below warmer air above. Specific 
information on the extent and duration of these 
conditions within the area is not available. 



Under the Clean Air Act Amendments of 1970, 
Oregon has been divided into five Federal Air 
Quality Control Regions (AQCRs) on the basis of 
pollution concentrations, geography and 
economics. The EIS area is in the southwest 
Oregon AQCR. Air quality in this area is good and 
meets all air quality standards (ODEQ 1981 ). 

Provisions of the Clean Air Act Amendments of 
1977 were made to ensure that areas with clean air 
do not suffer deteriorating air quality. Mandatory 
Class I areas are Crater Lake National Park and 
Diamond Peak, Kalmiopsis, Mt. Washington, Three 
Sisters, and Mt. Jefferson Wilderness areas. The 
SYUs and surrounding areas are designated Class 
II, which allows only moderate deterioration of air 
quality. 

The only sampling site within the EIS area is 
located in Roseburg. Since 1971, total suspended 
particulate levels have exceeded secondary 
Federal health standards (more than 150 
micrograms per cubic meter (ug/m 3 )) 14 times and 
have once violated primary standards (more than 
260 ug/m 3 ) (ODEQ 1981). The annual geometric 
mean for total suspended particulates has ranged 
from 64.7 micrograms per cubic meter (ug/m 3 ) in 
1974 to 46.0 ug/m 3 in 1980 (ODEQ 1981). See 
Table 2-1. 

Occasionally, smoke from slash burning in the 
SYUs has been visible in the population centers of 
Roseburg and Eugene-Springfield (ODEQ 1981). 
Slash smoke problems (visible smoke) in Douglas 
County are shown in Table 2-2. 



Table 2-1 Total Suspended Particulates in Roseburg 






(mic 


rograms per cu 


bic 


meter, 


ug/m 


3 ) 










Days 














Exceeding 




Annual 








No. of 


Standards 




Geometric 


24 Hour 


Averages 


Year 


Samples 


150 


260 1 




Mean 


Maximum 


2nd Highest 


1971 


98 


2 







51.2 


185 


180 


1972 


88 


2 







59.3 


222 


162 


1973 


58 


4 







52.9 


233 


181 


1974 


57 


4 


1 




64.7 


263 


258 


1975 


52 










43.9 


93 


89 


1976 


51 










47.8 


140 


121 


1977 


60 


1 







52.0 


170 


170 


1978 


60 










51.4 


104 


103 


1979 


32 










- 


109 


92 


1980 


60 


1 







46.0 


157 


137 


'Secondary standard = >150 ug/m 


'; primary standard = -260 i 


jg/m 3 . 






Source: 


ODEQ 1981 















29 



Table 2-2 Slash Smoke Problems 


in Douglas County 






Year 




No. of Burns 


Acres 


Tons of Slash 


Number of Problems 

Total BLM Days 


1976 

1977 
1978 
1979 
1980 
1981 




630 
601 
641 
603 
690 
141 


24,986 
21,542 
25,617 
24,103 
26,507 
3,742 


686,523 
888,965 
1,042,245 
909,172 
756,713 
51,457 


14 
4 
9 


29 



1 


5 



12 




1 


3 

1 



Source: 


ODEQ 1981; 


OSDF Annual Reports 


of Oregon Smoke Ma 


nagement Plans, 1977 thi 


-ough 1982. 







Geology and Topography 

The SYUs are located within the Coast Range, 
the Klamath Mountain and the Western Cascades 
physiographic provinces (Figure 2-1). The Coast 
Range is made up of submarine basalts and 
marine sediments of the Tyee and Umpqua 
Formations. The Klamath Mountain province is 
geologically complex, consisting of marine 
sediments, plutonic and volcanic rocks that have 
been folded, faulted and metamorphosed. The 
topography is rugged due to the resistant type of 
rock found there. Serpentine is fairly widespread 
in the Klamath Mountains, and extends 
northeasterly from the Cow Creek area through 
the central and southern part of the SYUs. Granite 
and diorite bedrock are found in several large 
areas in the southeastern part of the SYUs. These 
erode easily, creating steep, short sideslopes and 
sharp ridges. 

Also found in the Klamath Mountain province are 
thickly bedded sandstone and thin interbeds of 
mudstone, volcanic rock sometimes called 
greenstone because of the abundance of chlorite, 
and a chert pebble conglomerate overlain by 
sandstone, siltstone and conglomerate. The 
Western Cascade Province is characterized by a 
rugged topography with irregular ridges and deep 
narrow valleys. The rocks are mostly volcanics. 
Intrusive rock bodies in the Western Cascades are 
generally small and consist of plugs, dikes, sills 
and domes. 

Throughout the SYUs, slopes range from percent 
to vertical and average about 60 percent. Over 40 
percent of the area has slopes in excess of 65 
percent. Elevations range from 150 feet at Elkton, 
500 feet at Roseburg and 650 feet at Myrtle Creek 
to 2,800 feet at Baughman Lookout, 3,900 feet at 
Dutchman Butte, 4,400 feet at Deadman Mountain 
and 4,800 feet at Huckleberry Mountain. 

Soils 

The "Soils of the Roseburg District" (Wert 

et al. 1977) describes the soils resource of the EIS 

area in detail. A generalized soils map, which 



contains 14 broad groupings of soils, is shown as 
Figure 2-2. This map is useful only to show a 
general view of the major soils in the Roseburg 
SYUs. Soil moisture and soil temperature directly 
influence the ability of the soil to support plant life. 

Soils within the SYUs are generally capable of 
producing abundant plant growth. Most soils have 
a high content of organic matter, moderate to high 
nutrient levels and medium bulk densities (1.1 to 
1.3 gm/cm 3 ). Soils at high elevations, however, are 
often low in organic matter and nitrogen. 

Dry ravelling of soil materials, landslides and soil 
surface erosion occur naturally throughout the 
Roseburg SYUs. Total soil loss from these factors 
in the undisturbed forests is estimated to be 0.15 
to 0.40 tons per acre per year (t/ac/yr). Soil loss 
and loss of soil productivity have accelerated as a 
result of timber harvesting and road building. 
District experience has shown that in areas where 
road construction and harvests have taken place 
and regrowth is now established, soil loss is about 
1 to 3 t/ac/yr. In typical areas where tractor 
logging and downhill yarding have been practiced, 
erosion is estimated to be 230 t/ac/yr initially, 
reducing to an estimated 5 to 10 t/ac/yr after three 
to five years, finally stabilizing at an estimated 1 to 
3 t/ac/yr in about two decades. During the past 
decade soil productivity has been reduced on 
9,279 acres of BLM-administered land (5,276 acres 
by harvest and yarding methods that compact the 
soil and 3,553 acres bared by road construction 
activities). Table 2-3 shows totals within the 
Roseburg District. 

Fragile soils are found throughout the Roseburg 
SYUs. These soils include 33,547 acres of granitic 
soils or other soils that have a high potential for 
mass-failure and 138,711 acres of soils on very 
steep slopes with inclusion of unstable headwalls. 
These acres and the percentages of the BLM area 
are shown in Table 2-4. 

Mass movements tend to occur in draws where the 
slopes are steep and the soils are extremely 
fragile. Fragile soils are mostly shallow (less than 
20 inches to bedrock), have greater than 35 



30 



percent by volume of coarse fragments (rock and 
gravel), occur on slopes of 60 to 80 percent or 
greater and have low water-holding capacity and 
moderately rapid permeability. 

The two major kinds of mass movement of soils in 
the Roseburg SYUs are slumps and debris 
avalanches. Slumps are one or more blocks of soil 
that have rotated out of a hillside along a bowl- 
shaped failure plane. Debris avalanches are the 
rapid movement of incoherent soil, rocks and 
forest debris down steep draws. Soils that are 
associated with debris avalanches are usually 
those loamy and/or gravelly soils formed over 
decomposing granitic bedrock, sandstone, hard 
tuffs or breccias on 70 percent or greater slopes. 
Debris avalanches occur on the following soils in 
the SYUs: Holland and Siskiyou (slopes over 70 
percent); Digger, Jason and Umpcoos (over 75 
percent slopes); Larmine, Atring, Kilchis, 
Harrington, Chamate and Shippa soils (slopes over 
80 percent). 



Table 2-3 Bared Soils and Road 
Surfaces 

Failing cut-and-fill slopes and soil 
mass-movements 700 acres 

Unsurfaced roads causing erosion 600 acres 

Road surface 12,000 acres 

Totals 13,300 acres 



Footnote 

Estimates based on district soil scientist field experience and 

observations 



Water Resources 

The SYUs lie within four major river basins. 
There are 188,440 acres of BLM-administered land 
drained via the South Umpqua River, 65,100 acres 
drained via the North Umpqua River, another 
154,900 acres are drained by the main stem of the 
Umpqua River and 14,560 acres are drained by the 
Middle Fork Coquille River. Within these large 
watersheds, smaller sub-watersheds have 
problems with debris, sedimentation, bank erosion 
and elevated temperatures. The rivers and creeks 
with severe problems are shown in Table 2-5. 
Water quality problems in the SYUs are non-point 
source pollution resulting from debris, 
sedimentation, bank erosion and elevated 
temperatures. High sediment loads and 
streambank erosion occur during periods of peak 
flow (winter and spring), while problems of 
elevated temperatures, low dissolved oxygen and 
nuisance algae occur during periods of low flow 
(summer). Streamflow data collected at gauging 
stations within or nearby the SYUs are given in 
Table 2-6, Streamflow Data. 

Table 2-7 shows water and sediment discharge 
measured at selected gauging stations throughout 
the SYUs. The sediment yield ranges from 0.4 tons 
per acre at Olalla Creek near Tenmile to 3.0 tons 
per acre at the mouth of Lookingglass Creek. 
These values represent a long-term average and 
may differ greatly from year to year. Peak yields 
occur during the period of high runoff. 

Sediment losses from the SYUs depend on the 
changing combination of many watershed 
variables. Within the SYUs, which are mostly 
forested, a small portion of the sediment produced 
is attributable to purely natural forces. This loss 
represents the geologic rate of erosion. 



Table 2-4 Fragile and Problem Soils 








Problem 


Figure 2-2 
Color 


Acres 


Percent 
of SYUs 


Soils on very steep slopes with inclusion of unstable 
headwalls. 


Blue 


138,711 


33 


Soils on very steep slopes with inclusion of unstable 
headwalls and a high potential for failure when trees are 
removed. 


Green 


4,639 


1 


Granitic soils with severe surface erosion and inclusion 
of unstable headwalls. 


Yellow 


24,481 


6 


Granitic soils on very steep slopes with inclusion of 
unstable headwall and a high potential for failure when 
trees are removed. 


Green 


4,426 


1 


Footnote 

Due to map scale (Fig. 2-2) it is not possible to delineate individual fragile sites 









I 



Lookout Poirrr 

4-X 



WILLAMETTE 




iv'T^ 






> 



11 



\W 



Bu/nl Pea* * 

Li 



FIGURE 21 
PHYSIOGRAPHIC PROVINCES 



U. S DEPARTMENT OF THE INTERIOR 

BUREAU OF LAND MANAGEMENT 

ROSEBURC DISTRICT 

DOUGLAS AND SOUTH UMPQUA 
SUSTAINED YIELD UNITS 

Roseburg Environmental Impact Statement Area 

1982 



UDICMESIC SOILS 

1 Digger- Jason- Preacher Association 

2 Honey grove-Peavine-Preacher Association 

3 Honeygrove-Shtvigny Association 

4 Klickitat-Harrington Association 




FIGURE 2-2 
GENERAL SOILS 




U. S. DEPARTMENT OF THE INTERIOR 

BUREAU OF LAND MANAGEMENT 

ROSEBURG DISTRICT 

DOUGLAS AND SOUTH UMPQUA 
SUSTAINED YIELD UNITS 

Roseburg Environmental Impact Statement Area 

1982 



35 



Table 2-5 Severe Water Quality Problems 
















Water 








Elevated 


Withdrawals 




Severe 




Water 


Causing 




Sedimen- 


Streambank 


Temper- 


Quality 




tation 


Erosion 


atures 


Problems 


Cow Creek 


X 




X 


X 


North Myrtle Creek 


X 


X 


X 


X 


South Myrtle Creek 


X 


X 


X 


X 


South Umpqua River 


X 


X 


X 


X 


Twelvemile Creek 


X 








Elk Creek 


X 




X 


X 


Smith River (Headwater) 


X 


X 


X 




Tenmile Creek 


X 




X 


X 


Lookingglass Creek 


X 




X 


X 


Olalla " 


X 




X 


X 


Middle Fork Coquille River 






X 


X 


Sutherlin Creek 






X 


X 


Rock Creek 


X 


X 


X 




Canton Creek 




X 


X 




Canyon Creek 


X 




X 


X 


Days Creek 


X 




X 


X 


Little River 






X 


X 


Source: ODEQ Aug. 1978 











Groundwater supplies are highly variable and 
limited. Most wells produce only enough water to 
supply single households, and some may go dry 
during the summer. In the Drain-Yoncalla area, 
water supply is very poor. In the Willis and Rice 
Creek Drainages, groundwater supply is almost 
non-existent. Cow Creek has one of the better 
groundwater supplies in the county. Winston, 
Dillard, Tenmile, Elkton and Olalla have fair 
supplies. 

Heavy irrigation withdrawals are taken from Elk 
Creek, Calapooya Creek and the Umpqua River 
and throughout the South Umpqua River system. 
Bear Creek and Adams Creek watersheds, located 
near Drain and Yoncalla, are used as sources for 
domestic water supply by these two communities. 
In addition, several communities withdraw water 
for domestic use. The Roberts Creek Water District 
has rights on the South Umpqua River, the South 
Umpqua Water Association has rights on Cow 
Creek and serves 40 percent of Canyonville and 
the area between Riddle and Canyonville. The 
remainder of Canyonville uses O'Shea Creek and 
West Fork of Canyon Creek. Myrtle Creek uses the 
South Umpqua River as a backup source, and the 
Tri-City Water Association has rights on the South 
Umpqua. Riddle uses Judd, Cow and Russell 
Creek watersheds for municipal water supplies. 



Vegetation 



The SYUs are located in the Northwest 
Coastal Coniferous Sub-biome, which is the most 
densely forested region in the Coniferous Biome. 
Characterized by easy regeneration and rapid 
growth, it produces trees of impressive sizes. The 
lower vegetative layers are usually poorly 
developed except where open canopies encourage 
a lush understory of grasses, shrubs and 
herbaceous species. Additional information may 
be found in the BLM Timber Management FEIS. 

Terrestrial Vegetation 

For purposes of this EIS, vegetation is 
generally described in terms of "zones" adapted 
from those identified by Franklin and Dyrness in 
Natural Vegetation of Oregon and Washington 
(1973). A detailed description of each zone and 
plant community listed below may be found in that 
source or from data prepared in the Roseburg 
District. A complete list of common and scientific 
names for all plants discussed is available upon 
request. 

Portions of three major vegetative zones, Mixed 
Conifer, Western Hemlock and Interior Valley, are 
found within the SYUs. 

The southern portion of the SYUs above 1,000 feet 
in elevation is generally occupied by the Mixed 
Conifer Zone. Approximately 50 percent of BLM- 
administered lands in the SYUs lie within one of 
the following three major plant communities. 



36 



Table 2-6 Streamflow Data 










Location 


Average Discharge/Yr 

(CFS) (Ac. Ft.) 


Peak 

(CFS) 


Discharge 

(Date) 


Minimum 

(CFS) 


Discharge 

(Date) 


Cow Creek 
(Riddle) 


898 


650,600 


41,100 


Oct. 1950 


7.4 


Aug. 1977 


Olalla Creek 
(Tenmile) 


94.2 


68,200 


12.300 


Dec. 1955 





several yrs. 


Tenmile Cr. 
(Tenmile) 


64.4 


46,700 


3,650 


Jan. 1971 





several yrs. 


Lookingglass 
Cr. (Brockway) 


287 


207,900 


35.000 


Dec. 1955 





several yrs. 


Steamboat Cr. 
(below Canton 

Cr.) 


741 


536,900 


51,000 


Dec. 1964 


30 


Sept. 1973 


Rock Cr. (above 
fish hatchery) 


373 


270,200 


22,800 


Dec. 1964 


14 


Sept. 1966 


Little River 
(Peel) 


475 


344,100 


22,700 


Nov. 1953 


14 


several yrs. 


N. Umpqua R. 
(Winchester) 


3,746 


2,714,000 


150,000 


Dec. 1964 


383 


Sept. 1960 


Calapooya Cr. 
(Oakland) 


485 


351,300 


26,600 


Nov. 1961 





1966, 1974 


Umpqua River 
(Elkton) 


7,504 


5,437,000 


265.000 


Dec. 1964 


640 


July 1926 


Elk Creek 

(Drain) 


227 


164,400 


15,000 


Feb. 1961 





several yrs. 


Smith River 
(Gardiner) 


976 


547,700 


26,000 


Feb. 1961 


4.3 


Aug. 1966 


S. Umpqua R. 
(Tiller) 


1,042 


754,900 


60,200 


Dec. 1964 


20 


Sept. 1911 


Elk Creek 
(Drew) 


85.6 


62,020 


8,880 


Dec. 1964 





1974, 1977 


Days Creek 
(Days Creek) 


44.4 


32,170 


3,450 


Feb. 1956 





Jl/Ag 1961 


S. Myrtle Cr. 
(Myrtle Cr.) 


65.9 


57,740 


3,050 


Dec. 1956 


0.2 


Aug. 1961 


N. Myrtle Cr. 
(Myrtle Cr.) 


74.2 


53,760 


3,260 


Jan. 1964 





1973, 1977 


S. Umpqua R. 
(Brockway) 


2,899 


2,100,000 


125,000 


Dec. 1964 


16 


Aug. 1977 


Source: USDI. BLM Roseburg 


District URA 1980a (as of 1978 water year) 









37 



Table 2-7 Sediment Discharge Data 








Location 


Mean Annual 
Suspended Sediment Discharge 


Maximum 


Observed 


Discharge 
(Tons/Year) 


Concentration 
(Mg/L) 


Yield 
(Tons/ Ac) 


Concentration 
(Mg/L) 


Discharge 
(Tons/Day) 


Steamboat Cr. 
(below Canton Cr.) 


210,000 


240 


1.2 


3,870 


106,000 


N.Umpqua R. 
(Winchester) 


800,000 


120 


1.0 


768 


71,200 


Umpqua River 
(Elkton) 


3,500,000 


370 


1.5 


927 


196,000 


Elk Creek 
(Drain) 


74,000 


230 


1.1 


2,930 


9,730 


Olalla Creek 
(Tenmile) 


16,000 


150 


0.4 


3,600 


3,040 


Lookingglass 
Cr. (Brockway) 


310,000 


890 


3.0 


2,600 


35,100 


S. Umpqua R. 
(Brockway) 


1,700,000 


500 


1.6 


1,800 


208,000 


S. Umpqua R. 
(Tiller) 


140,000 


120 


0.5 


1,260 


65.100 


Cow Creek 
(Riddle) 


370,000 


370 


1.3 


1,360 


64,600 


Source: USDI, BLM 1980a. 













a. White fir, western hemlock, vine maple, western 
yew 

b. White fir, Douglas-fir, Whipple vine 

c. Douglas-fir, incense cedar, pine-mat manzanita. 

Frequent associates to these plant communities 
which are also important to the forest industry 
include sugar pine, ponderosa pine, western 
redcedar and western white pine. 

The Western Hemlock Zone extending throughout 
the northern portion of the SYUs at all elevations, 
covers approximately 47 percent of BLM- 
administered lands in the EIS area. It is famous for 
its subclimax species, Douglas-fir, which is often 
the sole dominant tree in the forest. As a pioneer 
species, Douglas-fir normally constitutes a serai 
(successional) stage during the vegetative 
community development process. This zone 
encompasses six major plant communities with 
various associations of trees, shrubs and forbs 
relative to specific climatic conditions such as 
aspect, moisture, soil type and depth, etc. These 
communities are listed on a site moisture gradient 
from dry to wet: 



a. Douglas-fir, ocean spray 

b. Western hemlock, golden chinkapin 

c. Western hemlock, Pacific rhododendron, salal 

d. Western hemlock, Pacific rhododendron, 
Oregon grape 

e. Western hemlock, swordfern, Oregon oxalis 

f. Western redcedar, western maidenhair fern, 
ladyfern 

The Interior Valley Zone includes the lowlands and 
valley bottoms enclosed by the Cascade'and Coast 
Ranges. Approximately 3 percent of BLM- 
administered lands occur within this zone at 
elevations up to 1,300 feet. Plant communities vary 
from grasslands and oak-madrone woodlands in 
low areas to conifer forests on the slopes. 
Frequent associates to these plant communities 
are Douglas-fir, ponderosa pine, incense cedar, 
ocean spray, Oregon grape and rye grasses. 

Riparian habitat occupies the transitional 
terrestrial areas from the water's edge to the 
better-drained slopes. Vegetation in these areas 
ranges from a few aquatic species and the 
hardwood-western redcedar-hemlock type, to the 
predominant Douglas-fir stand usually found on 
the slopes. 



38 



Habitat stratification for all forested land of the 
entire Roseburg Area is depicted in Table 2-8. The 
entire Roseburg Area includes all lands in Douglas 
County east of the crest of the coast range. 
Acreages listed are a composite of all ownerships 
obtained from several sources (USFS; OSDF; 
OSDT) as well as the BLM forest inventory. The 
acreages of BLM-administered lands are shown for 
comparison. 



Table 2-8 Existing Forest Habitat 
Stratification of Entire Roseburg 
Area (Acres) 


Habitat Age 


BLM 


All Lands 


Grass/Forb 
(non-stocked and 
0-7 years) 


34,100 


213,900 


Brush/Seedling 
(8-15 years) 


40,900 


239,100 


Pole/Sapling 
(16-45 years) 


56,400 


356,800 


Young 2nd Growth 
(46-115 years) 


82,200 


258,900 


Mature 
(116-195 years) 


79,800 


121,500 


Old Growth 
(196+ years) 


110,900 


234,100 


Source: USDI. BLM; USDA, FS; Oregon State Department of 
Forestry; Oregon State Department of Transportation (Parks and 
Recreation Branch) 



The old-growth forests existing today are complex 
ecosystems which have evolved by natural 
selection through successional stages during the 
vegetative community development process. 
Evidence now points to the simultaneous evolution 
of mycorrhizal tree hosts, hypogeous fungi, and 
small mammals that function as a transport 
mechanism for the fungi. 

Research required to fully understand the 
relationships and importance of these processes to 
long-range timber production has not yet been 
completed. It now appears that dispersal of 
mycorrhizal fungi by small mammals may be a 
critical factor in forest plantation establishment 
and survival in some instances (Maser et al. 1978). 
The functioning of the old growth forest as a 
system, however, has not yet been studied in 
depth. As recently as 10 years ago, nothing was 
known about sources of nitrogen in old growth 
stands. It is now known that lichens which inhabit 
the canopy of live old growth trees fix significant 
amounts of nitrogen which ultimately become 



available to the whole forest through leaching, 
litter fall and decomposition. Also, lichens and 
wood-dwelling bacteria on standing dead trees 
and logs have recently been identified as 
significant sites of nitrogen fixation (Franklin et al. 
1981). 

Seed zones are accepted as generally 
encompassing a geographic area within which the 
factors affecting reforestation and subsequent 
growth are relatively homogeneous (Appendix A). 
Seed zones and elevational intervals involving 
BLM-administered lands in the Roseburg SYUs are 
shown in Table A-1. 

Wetland and Aquatic 
Vegetation 

Wetlands are those areas inundated by 
surface or ground water at a frequency sufficient 
to produce a saturated or seasonally saturated soil 
condition. Examples of wetlands include marshes, 
swamps, bogs, wet meadows and natural ponds. 
Sedges, grasses, rushes, skunk cabbage, cattails 
and algae are typical wetland and aquatic plants. 

Sensitive, Threatened and 
Endangered Plants 

Endangered plants are those species that are 
in danger of extinction throughout all or a 
significant portion of their range. Threatened plant 
species are those that presently are not 
endangered but are likely to become so within the 
foreseeable future throughout all or a significant 
portion of their range. Sensitive plants are those 
species not yet officially listed but undergoing a 
status review (see Glossary-Sensitive Species). 

Botanical surveys for sensitive, threatened and 
endangered plants were conducted on the 
Roseburg District from 1978 through 1980 and are 
continuing. At present, one federally listed 
endangered plant (Arabis macdonaldiana, 
McDonald's arabis) is suspected to occur in the 
EIS area, but as yet remains unobserved. Several 
species observed in the EIS area are currently 
under review for listing as threatened or 
endangered by the U.S. Fish and Wildlife Service 
(Table 2-9). The final status of these species will 
be determined as sufficient data are collected. 



39 



Table 2-9 Sensitive Species Currently Under Review For Possible Listing 






Candidate 


Observa- 


Scientific Name 


Common Name 


for 1 


tions 2 


Arabis koehleri 


shrubby rockcress 


E 


B 


var. koehleri 








Aster vialis 


wayside aster 


E 


C 


Calochortus greenei 


Green's mariposa-lily 


T 


B 


Calochortus howellii 


Howell's mariposa-lily 


T 


B 


Camassia leichtlinii 


great camas 




A 


var. leichtlinii 








Cypripedium californicum 


California lady's slipper 


T 


B 


Cypripedium montanum 


mountain lady's slipper 


T 


A 


Darlingtonia californica 


California pitcherplant 


T 


C 


Dicentra formosa 


Oregon dicentra 


E 


C 


(spp. oregana) 








Frasera umpquaensis 


Umpqua swertia 


T 


C 


Kalmiopsis leachiana 


kalmiopsis 




C 


Lathyrus holochlorus 


thin-leaved peavine 


T 


B 


Lewisia cotyledon 


imperial lewisia 


T 


B 


var. howellii 








Limnanthes gracilis 


slender meadow-foam 


T 


B 


var. gracilis 








Mimulus pygmaeus 


pygmy monkey flower 




C 


Perideridia erythrorhiza 


false caraway 


T 


B 


Phacelia capitata 


scorpion weed 


T 


A,B 


Phacelia verna 


Umpqua phacelia 


T 


A,B 


Plagiobothrys hirtus 


rough allocarya 




C 


fspp. hirtus) 








Romanzoffia thompsonii 


romanzoffia 


T 


A 


Sidalcea cusickii 


Cusick's checker-mallow 


T 


B 


Synthyris missurica 


Howell's grouse flower 




C 


(spp. hirsuta) 








Thlaspi montanum 


pennycress 


T 


A,B 


var. siskiyouensis 








Viola lanceolata 


western bog violet 


T 


C 


var. occidentalis 








' Threatened (T). endangered (E), undesignated to date (blank). All species are designated as 


Bureau Sensitive Species by the Oregon State 


Director 








■ Observed; on BLM-A. on other lands in the SYUs - B, Unobserved - C. 







Animals 
Terrestrial Animals 

Animal distribution, diversity and abundance 
are dependent on various factors: of primary 
importance is vegetation. Each vegetational zone 
described in the previous section contains a 
variety of plant communities which may be in 
different successional stages. Each successional 
stage has a unique structure, and it is primarily 
this structure to which animal communities 
respond. The differences in communities, 
successional stages and structure provide habitat 
diversity and account for the variety of animals 
found in the planning area. 



Successional stages are dynamic. They are always 
progressing toward their climax form, and during 
this progression their animal components are also 
changing. Progress toward climax can be curtailed 
at any point by outside influences, either natural or 
artificial. For instance, fire or logging may set back 
succession, and those animal species associated 
with the current stage will be replaced with those 
adapted to exist in the early successional stages. 

Modifying or removing one particular stage, e.g., 
old growth, has a significant effect on those 
individuals and species occurring there. It is 
recognized that these effects do not stop with just 
those species, as the ecosystem as a whole is 
altered by the modification of one of its parts. 
Certain results may be harmful to some species 
and beneficial to others, but all are affected. 



40 



There are 32 species of amphibians and reptiles, 
184 species of birds and 70 species of mammals 
that occur or probably occur in the planning area. 
Some species of animals are quite restricted in 
their habitat requirements, while others have a 
wide tolerance. For instance, the robin occurs in 
most habitat types while the northern spotted owl 
is much more restricted. 

Appendix D lists those species of terrestrial 
vertebrates occurring in the planning area, some 
information on their habitat requirements and what 
is known of the status of their population and 
habitat. 

From the perspective of all ownerships, the 
progression toward climax on intensively managed 
lands in the SYUs has been halted and reverted to 
early successional stages by planned timber 
management activities. In 1930, for example, most 
of the forest land acreage supported mature and 
old growth stands. The most recent inventories 
(Appendices E and F) show (Table 2-8) a greater 
diversity than that which existed under more 
"natural" conditions 50 years ago. 

The present diversity, however, is a transitory 
condition. The forest management activities that 
created the current diversity on the commercial 
forest land base will, if carried to the planned 
conclusion, result in a situation where the oldest 
forest stands will be 80 years of age. Since 
approximately 71 percent of the area is not 



controlled by the BLM, this is the situation that is 
most likely to occur on most of the area. 

Habitat structure for all lands within the SYUs 
regardless of ownership or administration cannot 
be accurately calculated. However, based on data 
from a variety of sources, habitat structure for the 
entire area was estimated for all forest lands and is 
shown in Table 2-10. The "all lands" category 
consists of forest lands within Douglas County 
east of the crest of the Coast Range. Total land 
area is approximately 1.4 million acres. Bureau 
forest lands in the table approximate 404,000 
acres. 

Old-growth forests provide optimum habitat for a 
variety of animal species (see Appendix D) and are 
important to the entire forest ecosystem (Franklin 
etal. 1981). Old-growth habitat totals 110,900 
acres or 27 percent of Bureau-managed forest 
lands in the SYUs (Tables 2-8 and 2-10). 

Other types of habitat exist and can be modified 
by forest management practices. Of special 
concern are snags. Snags provide optimum habitat 
for 33 species and are used to some extent by 47 
other species of birds and mammals in the SYUs 
(see Appendix D). That cavity-nesting birds feed 
on insects and play an important part in control of 
forest insect pests has been well reviewed by 
Thomas (1979). 



Table 2-10 Habitat Structure of Forest Lands 


in 


the SYUs (by percent) 












BLM Habitat 


Habitat Age 




All Forest 
Lands 




BLM 


as a 
Percent of All 
Forest Lands* 


Grass/Forb 
(non-stocked and 0-7 


years) 


15 




9 


16 


Brush/Seedling 
(8-15 years) 




17 




10 


17 


Pole/Sapling 
(16-45 years) 




25 




14 


16 


Young 2nd Growth 
(46-115 years) 




18 




20 


32 


Mature 
(116-195 years) 




9 




20 


66 


Old Growth 
(196+ years) 




16 




27 


47 


" This column indicates, for example, that while 27 percent of BLM land is old growth, this is 47 percent of all 


old growth in the defined area 


Source: USDI, BLM. USOA. FS 


; Oregon Department of Forestry; 


Oregon Division of Parks and Recreation 





41 



Under natural conditions, snags occur throughout 
the forest as a result of fire, disease and other 
factors. Timber harvest practices generally result 
in their removal for safety and fire prevention. 
Recent snag surveys by district personnel revealed 
an average of 0.1 snags per acre in coniferous 
forests less than 15 years of age under BLM 
administration. Due to the large amount of older 
forest lands, snag densities are currently at high 
levels, although distribution is not even. 

Riparian zones are an extremely important habitat 
because they are used to a greater extent by a 
greater variety of species than any other habitat. 
Of the 286 species of terrestrial vertebrates found 
in the planning area, 82 find their optimum habitat 
in riparian zones while another 170 species use 
this habitat for part of their overall needs (see 
Appendix D). 

In western Oregon riparian zones vary in width; 
generally, the larger the stream the wider the 
riparian zone. Vegetation within these areas 
includes plants only found in association with 
water as well as others including hardwoods and 
merchantable softwoods. 

Currently, there are about 22,800 acres of riparian 
habitat on BLM-administered lands in the SYUs 
(USDI, BLM 1980a). Approximately 12,150 of these 
acres are along small first and second order 
streams. Because of the intermittent nature of 
these streams, the riparian habitat is not as well 
developed as on larger rivers and is more nearly 
like the adjacent upland habitat. 

The riparian habitat on third order and larger 
streams represents about 3 percent of the forest 
land base. Some of this has been altered by past 
timber management practices and is in less than 
optimum condition. 

Elk are not evenly distributed. While limited 
numbers in scattered herds do occur in the other 
areas, elk are concentrated in the Tyee area, which 
includes Powell, Basin, Wolf, Cougar and Hubbard 
Creek drainages. Habitat on BLM lands in this area 
is currently in the following condition: 



Forage Area 


Hiding and Escape 
Cover 


Thermal Cover 


Survival Cover 


0-15 years 


16-45 years 


46-120 years 


120* years 


15% 


17% 


12% 


56% 



* Survival cover can be substituted for thermal cover but thermal cover 

can not be substituted for survival cover 
Source USDI, BLM 1980a and district personnel. 

The mature and old growth components are 
important to elk if optimum or near optimum 
populations are to occur. In times of extreme 
temperatures they function as survival cover, 
providing forage, temperature moderation and 
snow interception (Jenkins and Starkey 1980, De 
Calesta and Witmer 1980, Smithey et al. 1982). 
Much of the adjacent land under other ownership 
has been cut over and provides forage and escape 
cover. It is primarily Bureau-managed lands that 



supply the thermal cover component. 

Fish 

Salmonids are the most important group of 
fish found in the SYUs. Other native species such 
as sculpins, suckers, dace and squawfish are also 
present within the area. 

Introduced species such as brown bullhead, 
smallmouth bass, largemouth bass and shad are 
also present and becoming an important fishery. 
With the exception of information concerning 
salmonids in the North Umpqua River, there is 
little population data available. There is even less 
available when limited to BLM land. It can be 
assumed that current habitat conditions and fish 
populations reflect past land management actions 
and fish harvest regulations. In the case of 
anadromous fish, the ocean habitat becomes a 
third component influencing population levels. 

Timber management on all lands has been the 
most significant land management action. 
Changes in timber management practices 
beginning in the 1960's and natural 
reestablishment of streamside vegetation on lands 
logged earlier have resulted in an improvement to 
stream fish habitat. 

To some extent, all salmonids have the same or 
similar habitat requirements such as temperature, 
dissolved oxygen, spawning habitat and food 
supplies. Although there are strong similarities in 
some streams, there are highly varied population 
levels when one species is compared to another 
(see Table 2-11). 

The North Umpqua Resource Area is rated as 
good spring cninook habitat and fair fall Chinook 
habitat. Both races have similar habitat 
requirements but the North Umpqua has never 
supported comparable populations. Similar 
comparisons can be made between summer and 
winter steelhead or steelhead and coho salmon. 

Recognizing these and other differences, Table 2- 
11 was prepared showing information by BLM 
Resource Area. Examples of streams in each 
resource area are as follows: 

Drain Resource Area: Smith River and Wolf 
Creek 

North Umpqua Resource Area: North Umpqua 
and Little River 

South Umpqua Resource Area: Myrtle Creek and 
Days Creek 

Dillard Resource Area: Cow Creek and 12 Mile 
Creek 



42 



Table 2-11 Salmonid Fish Habitat and Populations 



Drain Resource Area 

Miles of Habitat (BLM) 

Miles of Habitat (other ownership) 

Habitat Quality 

Wild Fish Population Trend 

Hatchery Supplement 

North Umpqua Resource Area 

Miles of Habitat (BLM) 

Miles of Habitat (other ownership) 

Habitat Quality 

Wild Fish Population Trend 

Hatchery Supplement 

South Umpqua Resource Area 

Miles of Habitat (BLM) 

Miles of Habitat (other ownership) 

Habitat Quality 

Wild Fish Population Trend 

Hatchery Supplement 

Dillard Resource Area 

Miles of Habitat (BLM) 

Miles of Habitat (other ownership) 

Habitat Quality 

Wild Fish Population Trend 

Hatchery Supplement 



Key 

E = Excellent 
G = Good 



Spring 


Fall 




Chinook 


Chinook 


Cohc 


9 


20 


79 


46 


66 


255 


1 


F 


P 


' 


S 


D 


No 


No 


2 


8 


8 


18 


71 


71 


105 


G 


F 


P 


S 


S 


D 


40%' 


No 




2 


2 


26 


46 


46 


142 


P 


P 


P 


D 


I 


D 


No 


No 


No 




6 


24 


— 


44 


147 


— 


P 

I 


P 
D 


— 


No 


No 



F = Fair 
P = Poor 



S = Stable 
I = Increase 



D = Decrease 



1 Only present during passage to and from the ocean. 

2 Release of hatchery reared smolts initiated but too soon for adult returns. 

3 Percentage of total adult run attributable to hatchery reared smolts. 

" Percentage of trout harvest attributable to hatchery reared legal sized fish. 

Source: USDI, BLM 1980a, and BLM district personnel. 



Winter 


Summer 






Steel- 


Steel- 


Sea-run 


Resident 


head 


head 


Cutthroat 


Trout 


79 


9 


79 


108 


255 


46 


255 


297 


F 




P 


F 


S 


' 


D 


D 


No 


No 


No 


No 


34 


28 


34 


57 


154 


45 


154 


275 


F 


G 


P 


F 


S 


S-l 


D 


S 


No 


50%' 


No 


95%' 


26 




26 


57 


142 


— 


142 


214 


P 


— 


P 


F 


S-l 


— 


D 


S-D 


50% 


— 


No 


95% 4 


24 




24 


48 


147 


— 


147 


162 


F 


— 


P 


F 


S-l 


— 


D 


D 


50% 


— 


No 


No 



Table 2-12 Threatened and 




Endangered Species of the 




Roseburg SYUs 


Federal 


Oregon 


Species 


Status 


Status 


Northern bald eagle 


T 


T 


Haliaeetus 






leucocephalus 






alascanus 






Northern spotted owl 




T 


Strix occidentalis 






caurina 






Columbian white-tailed deer 


E 


E 


Odocoileus virginianus 






leucurus 






T = Threatened 






E Endangered 







Threatened and Endangered 
Animals 

There are three species of animals 
officially listed by the U.S. Fish and Wildlife 
Service and/or the State of Oregon as threatened 
or endangered that occur at least occasionally in 
the SYUs. Table 2-12 lists those species and their 
status. 

The bald eagle is a regular inhabitant of the SYUs 
and there are two pairs known to nest on BLM- 
administered land. 

The northern spotted owl is a permanent resident 
of the SYUs. On Bureau-administered lands, there 
are 55 habitat units, each known to support one 
pair of owls. An additional 30 locations have been 
identified as occasionally containing owls. These 
may be juveniles or single birds. Inconsistent 
sighting and the quality of the habitat make it 
unlikely these areas are capable of supporting 
breeding pairs. 



43 



The 55 habitat units were judged to be in the 
following condition: 

Poor 4 Very Good 1 1 

Fair 12 Excellent 9 

Good 19 

The criteria used to judge the conditions were: 

Poor = <1 50 acres old growth 

1,050 acres <80 years 

Fair = <300 acres old growth 

900 acres <120 years 

Good = 300+ acres old growth 

450 acres 30-200 years 
450 acres <30 years 

Very Good = 500+ acres old growth 
200 acres 120-200 years 
200 acres 30-120 years 
300 acres <30 years 

Excellent = 700+ acres old growth 
200 acres 120-200 years 
100 acres 30-1 20 years 
200 acres <30 years 

In the opinion of the BLM district biologist, those 
units in the poor habitat category are extremely 
marginal and will eventually fail to support owls. 

An additional 63 pairs of owls have been recorded 
on lands of other ownership within the planning 
area, primarily on lands administered by the U.S. 
Forest Service. 

The Columbian white-tailed deer is a resident of 
the oak-ash bottom lands and the oak-madrone 
uplands and is found on Bureau-managed lands, 
but predominantly on lands in other ownerships. 

The U.S. Fish and Wildlife Service has not 
designated any critical habitat under Section 4 of 
the Endangered Species Act within the SYUs. 
However, BLM identified essential habitat totaling 
37 acres for the Columbian white-tailed deer and 
3,475 acres for the bald eagle was delineated in the 
SYUs and recommended to the U.S. Fish and 
Wildlife Service for further consideration. 



Recreation 



Developed recreation sites on public land include 
Gunter, Tyee, Lone Rock, Mill Pond, Rock Creek, 
Scaredman, Susan Creek Recreation Area, Cavitt 
Creek, Wolf Creek Trail and Emile (see Figure 1-1). 
Each site (except trails) has facilities for overnight 
camping and/or picnicking. Annual use at the 10 
developed sites is approximately 19,000 visitor 
days, with about 43 percent attributable to 
overnight use. Opportunities are also available for 
dispersed camping and picnicking throughout the 
SYUs. 



Fishing for anadromous species is a major 
recreational activity in the SYUs. Some fishing for 
trout and warm water game fish also occurs. Most 
stream fishing use is in the Umpqua (Main, North 
and South), Smith and Little Rivers, Rock Creek 
and Cow Creek. The North Umpqua River is 
nationally known for its anadromous fishery. 

The major hunting activity on public land is for 
deer and elk. Hunter success is affected by game 
populations, ease of movement and shooting 
opportunities. Hunting with hounds for bear and 
cougar also occurs throughout the SYUs. 

Most general sightseeing use occurs in association 
with travel along major roads. Some people also 
visit public lands with specific sightseeing goals or 
may include sightseeing as a part of other 
activities. Examples of such areas with 
opportunities for this use include the North 
Umpqua River Highway, Cavitt Creek Falls, Maude 
"S" Mine, Susan Creek Indian Mounds, Main and 
South Umpqua River, Susan Creek Falls, Wolf 
Creek Falls and a number of scenic overlooks. 

High quality opportunities are available for 
swimming, canoeing, kayaking and floatboating. 
Most use occurs on the Umpqua River (Main, 
North and South Forks) and Cow Creek. Off-road 
vehicle (ORV) use in the SYUs is generally limited 
to existing roads and trails. In recent years this 
recreational use has increased rapidly. Although 
use is low, opportunities are available for areawide 
berry picking and horseback riding, goldpanning 
and rock collecting. 

The Nationwide Rivers Inventory prepared by the 
Heritage Conservation and Recreation Service 
(HCRS) and National Park Service (NPS) has 
identified sections of the Umpqua and North 
Umpqua as potential national wild, scenic or 
recreational rivers crossing public land within the 
SYUs (USDI, HCRS 1980). The North Umpqua 
River has also been identified by the State of 
Oregon for potential State Scenic Waterway 
designation. The State Transportation 
Commission reviewed the study but chose not to 
continue the designation process for the North 
Umpqua River (Lilly 1981). 

Table 2-13 summarizes visitation attributable to 
major recreation activities in the SYUs. 
Recreational demand projections to 1990 are also 
displayed. 

Cultural Resources 

BLM is required by law and executive order 
to identify, protect and enhance significant 
cultural resources on public lands. A number of 
procedures, including those specified in 36 CFR 
800.4(a), were used to identify the cultural 
resources within the SYUs. 



44 



Table 2-13 Estimated Current and Projected Visitation Attributed to Major 
Recreation Activities 


Activity 




Current Visitation 1 
Visitor Days/Year 


1990 Demand Projection 2 
Visitor Days/Year 




Total 3 
(Douglas 
County) 


BLM 

(Roseburg 

District) 


Total 3 
(Douglas 
County) 


BLM 

(Roseburg 

District) 


Hunting 

Big game 
Upland game 




194,060 
35,120 


23,250 
2,510 


204,630 
37,330 


24,460 
2,670 


Fishing 

All anadromous 
Resident cold-water 
Resident warm-water 




124,000 

103,800 

5,200 


23,670 

19,190 

490 


186,000 
129,750 
10,400 


35,510 

23,990 

980 


Camping 
Hiking 

Horseback riding 
Hound sports 
ORV use 
Other day use 4 
Total 




796,300 

23,560 

25,390 

182,330 

500,330 

598,670 

2,588,760 


8,220 

420 

460 

3,280 

9,010 

10,780 

101,280 


978,000 

28,940 

31,180 

223,930 

614,500 

735,270 

3,184,930 


10,100 

520 

560 

4,030 

11,070 

13,240 

127,130 


1 Based on data collected between 1976-1978 

: Based upon projections in USDI, BLM (1980b), conversations with Oregon Department of Fish 

Transportation (1978) 

1 Total visitation includes use in the coastal region where public lands are limited. 

* Total area day use visitation excludes urban and semi-urban activities not generally associated 


and Wildlife staff and Oregon Department of 
with forest lands administered by BLM 


Source: USDI. BLM 1980b. 













A survey of existing cultural resource information 
(Class I survey) has been completed for the SYUs 
(Honey and Hogg 1980) through a compilation of 
the area's existing site record data. A thorough 
survey to locate and identify cultural resources is 
accomplished prior to ground disturbance or 
ownership changes. The results of this intensive 
survey are documented in each site specific 
environmental assessment. 

The criteria used to assess the eligibility of 
identified cultural resources for inclusion in the 
National Register of Historic Places are described 
in36CFR 1202.6. 

Prehistoric Sites 

While little of the area has been field 
surveyed for prehistoric resources due to its steep, 
heavily forested terrain, there are 90 recorded 
prehistoric sites on or near public land within the 
SYUs (Honey and Hogg 1980). Most are trailside 
and/or hunting camps associated with Indian use 
of upland resources. An area's available resources 
such as water, plant and animal foods, workable 
stone, or amenable terrain probably determined 
the nature and location of sites. 

Examples of areas within the SYUs which exhibit a 
relatively high density of prehistoric sites include 



Upper Little River, Susan Creek vicinity, Upper 
Middle Creek, Camas Valley-Boulder Creek and 
the White Rock-Dompier Creek Region. 

A group of rock mounds in the Susan Creek 
vicinity is currently listed on the National Register 
of Historic Places (see Glossary). 

Historic Sites 

There are 41 inventoried historic sites on 
or near BLM-administered land within the SYUs 
(Honey and Hogg 1980). About 80 percent of the 
sites have not been formally recorded and are in 
need of further documentation. Most historic sites 
in the SYUs relate to fur trade, settlement, 
transportation, mining and logging. None of the 
historic sites on public land is currently listed on 
the National Register of Historic Places. 

Paleontologic Sites 

No important or scientifically unique 
paleontologic sites have been identified in the 
SYUs. However, all reports of fossil-bearing 
deposits are examined by qualified personnel to 
avoid destruction of such resources. 



45 



Visual Resources 

Visual resources are the land, water, 
vegetation, animals and the other features (as 
described in this chapter) that are visible on public 
lands. Visual resource management (VRM) 
objectives have been developed based on three 
factors (BLM Manual 8400). These factors are 
scenic quality, visual sensitivity and distance zone 
(see Glossary). Examples of high to moderate 
scenic quality and visually sensitive areas on 
public land include Coles Valley, Umpqua River, 
Berry Creek Reservoir, Bushnell Rock, Susan 
Creek Falls, North Umpqua River, Cooper Creek 
Reservoir and portions of the viewshed from 
Interstate 5. 

VRM classes specify management objectives and 
allow for differing degrees of modification. 
Objectives for each VRM class follow: 

Class I: Provides primarily for natural ecological 
change (highest levels of protection). Generally 
includes highly scenic and/or highly sensitive 
areas. 

Class II: Changes in any of the visual resource 
basic elements (see Glossary) caused by a 
management activity should not be evident in the 
characteristic landscape. A change may be seen 
but should not attract attention (retention of 
scenic quality). Generally includes areas with high 
to moderate scenic quality and/or sensitivity. 

Class III: Changes in the basic elements caused by 
a management activity may be evident in, but 
should remain subordinate to, the existing 
characteristic landscape (partial retention of 
scenic quality). Generally includes moderate 
scenic quality and/or sensitivity. 

Class IV: Changes may attract attention and be 
dominant landscape features but should reflect 
those basic elements inherent in the characteristic 
landscape (modification of scenic quality - lowest 
level of protection). Generally includes areas with 
moderate to low scenic quality that are seldom 
seen. 

Figure 2-3 shows VRM classes as recommended 
through the visual resource inventory and 
evaluation of the existing environment. 

Wilderness Values 

Under the terms of the Federal Land Policy 
and Management Act of 1976 (FLPMA), roadless 
areas of 5,000 acres or more that have wilderness 
characteristics are to be reviewed within 15 years 
for possible wilderness designation. The 1976 Act 
also states that in the event of inconsistency 
between it and the O&C Act insofar as they both 
may relate to management of timber resources, the 
O&C Act prevails. Accordingly, the wilderness 



review provisions do not apply to revested Oregon 
and California Railroad grant lands suitable for 
sustained yield management as commercial timber 
lands. 

No areas within the SYUs are proposed wilderness 
study areas. The intensive wilderness inventory 
and accompanying maps for Oregon and 
Washington are available in the Oregon State 
Office. 

Areas of Critical 
Environmental Concern 

Areas of Critical Environmental Concern 
(ACECs) are areas within the public lands where 
special management attention is required to 
protect and prevent irreparable damage to 
important historic, cultural, or scenic values, fish 
and wildlife resources, or other natural systems or 
processes, or to protect life and safety from 
natural hazards (FLPMA Section 103(a)). 
Designation of an area as an ACEC does not 
necessarily preclude development but rather 
ensures the protection of sensitive values in those 
cases where appropriate development may take 
place. Following designation, activity plans are 
prepared to translate special management 
requirements for each area into on-the-ground 
implementation actions. 

Of the 15 areas nominated for ACEC consideration 
during the Roseburg District's planning process 
(see Table 2-14), seven were found to be qualified 
for ACEC designation. The decision to designate 
any or all of these areas as ACECs will be part of 
the Management Framework Plan decision for the 
SYUs, to be made following completion of this EIS. 



Special Areas 



The 28-acre Myrtle Island timber 
preservation area (see Glossary) was established 
in 1951 by Public Land Order Number 754 to 
preserve an old growth stand of Oregon myrtle. 
This Umpqua River island also has scattered old 
growth Douglas-fir (Franklin et al. 1972). Further, 
the area is a designated Research Natural Area 
(see Glossary). Myrtle Island has also been 
identified by the National Park Service (NPS) as a 
potential National Natural Landmark (Chilcoteet 
al. 1976). Designation of a site as a National 
Natural Landmark (see Glossary), a program 
administered by the NPS, is not a land withdrawal 
and would not affect BLM jurisdiction to manage 
the area. 

Beatty Creek is a designated Research Natural 
Area (RNA). This 173-acre area has a 
representation of Jeffrey pine on serpentine soil in 
the Siskiyou Mountains physiographic province. 



46 



Table 2-1 4 Nominated and Potential Areas of Critical Environmental Concern 



Approximate 
Site Name Size (acres) Description 

QUALIFIED FOR ACEC DESIGNATION 1 



Primary 
Resource Values 



Remarks 



1 Brad's Creek 


137 


2. Golden Bar 


217 


3. North Umpqua River 


1,620 


4. Tater Hill 


169 


5. Myrtle Island 


28 



6. Beatty Creek 



7. North Myrtle Creek 
(Slideover) 



Old growth forest, bald eagle habitat 

Old growth forest, bald eagle habitat, 
cultural resources 

Anadromous fishery, high scenic value 

Large, active landslide 



28 Old growth Oregon myrtle and Douglas-fir 



173 Pure stand of Jeffrey Pine and a grass 

community on serpentine soils at low 
elevation 

480 Coniferous forest mixture in the Umpqua 

River Valley 



Wildlife, Scenic 
Wildlife, Scenic 

Wildlife, Scenic 

Geologic Proposed 

Research Natural 
Area (RNA) 

Botanic, Scenic Currently 

designated RNA 
and timber 
preservation area 

Botanic Designated RNA 



Botanic 



Proposed RNA 
(240 acres) 



NOMINATED BUT NOT QUALIFIED FOR ACEC DESIGNATION 2 



1 Whistler's Woodlands 



22 



2. Bluff Creek Bluffs 


120 


3. Rice-Bushnell Divide 


40 


4. Canyon Mountain 


80 


5. North Myrtle Creek 
Watershed 


13,100 


6 Wood Creek 


360 


7. Dompier Creek 


240 



Oak woodlands, Columbian white-tailed Wildlife 
deer habitat 

Candidate threatened or endangered plant Botanic 

Candidate threatened or endangered plant Botanic 

Candidate threatened or endangered Botanic 
plants 

Large, geologically complex basin Natural Hazard 

Old growth timber, spotted owl habitat Wildlife 

Several landslides, slump ponds Geologic Hazard 



' Two identification criteria (relevance and importance) derived from the Federal Land Policy and Management Act (1976) were 
applied to evaluate all areas nominated for ACEC designation. While Myrtle Island, Beatty Creek and North Myrtle Creek met these 
criteria, other measures would be adequate to protect the significant resource values in these areas. Myrtle Island and Beatty Creek 
are currently designated Research Natural Areas. North Myrtle Creek is a proposed Research Natural Area. 

2 Areas failed to meet the criteria of importance, as described in the August, 1980 Final Guidelines for Areas of Critical Environmental 
Concern (USDI. BLM 1980d). 



Other areas with potential for RNA designation 
include Woodruff Canyon lands, Old Fairview, 
Tater Hill and North Myrtle Creek. The Little River 
Arch has potential for Outstanding Natural Area 
(see Glossary) designation. Red Pond is a 
proposed environmental education area. 

The BLM currently has five environmental 
education use permits on public land. These 
permits provide for environmental education and 



study of public land resources but do not involve 
special designation or facility development. 

Socioeconomic Conditions 

During 1975 through 1977 logs from the 
Roseburg District were trucked to destinations in 
Douglas (89.9 percent), Lane (7.3 percent), Coos 
(1.9 percent), Josephine (0.1 percent) and Jackson 
counties (0.8 percent). These five counties taken 




FIGURE 2-3 

VISUAL RESOURCE 
MANAGEMENT CLASSES 




U. S. DEPARTMENT OF THE INTERIOR 

BUREAU OF LAND MANAGEMENT 
ROSEBURC DISTRICT 

DOUGLAS AND SOUTH UMPQUA 
SUSTAINED YIELD UNITS 

Roseburg Environmental Impact Statement Area 

1982 



49 



together are evaluated here as the regional 
economy affected by the action. 

The region is divided by the Coast Range into an 
eastern section with a larger and more dispersed 
population in the Willamette, Umpqua and Rogue 
River Valleys and a western section with a smaller 
population concentrated near Coos Bay and in the 
Coquille River Valley. 

The average level and recent changes in 
population, employment, personal income and 
public revenue within the regional economy are 
the quantitative indicators of social well-being 
discussed below. Although this is not a complete 
list, these four indicators were selected because 
other indicators tend to move consistently up or 
down with them and these data have been 
tabulated similarly for a number of years. 

As shown in Table 2-15, the population of the 
region has increased more than 30 percent over 
the last decade and now exceeds 600,000. While 
paralleling a nationwide shift of population 
westward, the rate of growth in the region 

Table 2-15 Population, 1960-1980 



exceeded substantially the rate of growth in 
Oregon, which in turn exceeded the population 
growth rate in the United States. 

Seventy-four percent of the region's population 
growth has been net migration into the region 
(Seidel 1981). Surveys of recent immigrants imply 
that many are coming to southwestern Oregon in 
search of a perceived quality of life not found in 
major metropolitan areas but available in small 
urban and rural environments (Stevens 1981). A 
significant proportion of the newcomers 
immigrated to the region without having first 
secured employment (Stevens 1980). 

This immigration plus an increase in the 
proportion of women employed or seeking 
employment caused the labor force to grow faster 
than total employment (Table 2-16). For example, 
in Douglas County, the annual rate of job creation 
was 2.17 percent while the labor force was 
increasing at 2.91 percent annually. 



Annual Growth Rate 



County 


1960 


1970 


1980 


1960-70 


1970-80 


Douglas 

Lane 

Coos 

Josephine 

Jackson 


68,458 
162,890 
54,955 
29,917 
73,962 


71,743 
213,358 
56,515 
35,746 
94,533 


93,748 

275,226 

64,047 

58,820 

132,456 


0.5% 

2.7 

0.3 

1.8 

2.5 


2.7% 

2.6 

1.3 

5.1 

3.4 


Region 


390,182 


471,895 


624,297 


1 .9% 


2.8% 


Oregon 


1,768,687 


2,091,533 


2,633,105 


1.7% 


2.3% 


United States 


179,323,175 


203,235,298 


226,504,825 


1 .3% 


1.1% 



Source: U.S. Dept of Commerce Census of Population, years indicated. 



Table 2-16 Components of Population Change, 1970-1980 















County 




Population 

Change 

1970-1980 


Natural Increase 

(Births minus 

deaths) 


Net 
Migration 


Net Migration 

as a Percent of 

Population Change 


Douglas 

Lane 

Coos 

Josephine 

Jackson 




22,015 
59,825 
7,532 
23,109 
37,923 


7,332 
19,657 
4,391 
2,224 
5,867 


14,683 
40,168 
3,141 
20,885 
32,056 


67 
67 
42 
90 
85 


Region 




150,404 


39,471 


110,933 


74 


Source: Personal 
Oregon, Septemb 


communication, 
er 1981. 


Karen Seidel, Bureau 


of Governmental Research 


and Service, University of Oregon, Eugene, 



50 



Table 2-17 Average Size and Recent Growth of the Labor Force and 
Employment in Industries 







Douglas County 


Regional 


Regional Economy 




Oregon 






Compound 




Compound 




Compound 




Douglas County 


Annual Growth 


Economy 


Annual Growth 


Oregon 


Annual Growth 




Avg. 1977-1980 


1972-1980 O) 


Avg. 1977-1980 


1972-1980 ; 


Avg. 1977-1980 


1972-1980 (,) 


l abor Force 


38.800 


291 


270.500 


3 75 


1.202.500 


358 


Total Employment 


35.000 


2 17 


246.300 


3 23 


1.1 16,800 


3 38 


Wage & Salary Empl> 


BOO 


246 


210,900 




1.009.100 


3 77 


All Manufacturing 


1 0.200 


-1 46 


48.300 


53 


216.600 


1 92 


Lumber & Wood 


8.500 


-2 05 


35.100 


-2 64 


77.700 


-1 37 


' Durable Goods 


500 


-.81 


6.000 


602 






All Non-Manufacturing 


20.600 


4 75 


162,500 


4.87 


792,400 


4 30 




5.600 


4 44 


50.100 


5 10 


245.500 


4 67 


Services & Miscell.i 


4,300 


683 


35.900 


6 72 


1 78 600 


565 


Government 


6.900 


385 


46,000 


4 05 


196.400 


3 18 



' Not comparable with the same category for Douglas County or the Regional Economy 

Source Computations by EIS staff of data obtained from the Research and Statistics Section. Employment Division. Oregon Dept of Human Resources 



Table 2-18 Total and Rate of Growth of 


Labor and Proprietors' Income in 


Selected Industries Affected by Timber Management in 
District 


the Roseburg 




Douglas County 

Avg. 1977-1979 

(S1.000.000) 


Douglas County E 
Compound Annual 
Growth 1972-1979 


Regional 
conomy Avg. 
1977-1979 
(S1. 000.000) 


Regional Economy 
Compound Annual 
Growth 1972-1979 


Oregon 

Avg. 1977-1979 

(S1.000.000) 


Oregon 
Compound Annual 
Growth 1972-1979 


Total Labor and Proprietors' 














Income by place of work 


S 493 5 


1 1 .9 


S3.073.5 


12 96% 


S19.792 8 


1 1 40% 


Durable Goods Manufacturing 


197 


10 1 


837.1 


10.60% 


3.079 1 


11 79% 


Trade 


57.9 




555 2 


13.81% 


2,923.5 


11.25% 


Services 


52.9 


15 !., 


454.8 


15.62% 


2.381 9 


12 40% 


Federal Gov't., Civilian 


26 6 


10.99% 


1023 


12 


505 7 


7 97% 


State and Local Government 

Per Capita Personal Income 
(in actual $) 


253.1 
$7,012. 




3689 
S6.984 


12.55% 
10.24 


1.864 2 
S 8.047 


9 76% 
9 38% 


957% 


Source Computations by EIS staff 
1981. 


obtained from the Regional Economic Information system US. 


Department of Commerce, Bureau of Ecor 


lomic Analysis. April 



Employment and income growth in the region's 
trade and service sectors was strong in the 1970's 
(Tables 2-17 and 2-18). The growth rates in the 
region outpaced Douglas County, which was 
ahead of the State totals in both categories. A 
reduction of the manufacturing base in Douglas 
County and a lack of significant growth in 
manufacturing employment in the regional 
economy during the decade are of local concern 
(C.C.D. Economic Improvement Assoc. 1978, 
1979). Non-manufacturing employment within the 
region and the State has increased, paralleling a 
national trend. Whether projected long-term 
declines in lumber and wood products 
employment (Burden 1977; Flacco 1978; C.C.D. 
Economic Improvement Assoc. 1978) can be offset 
by continued growth in the non-manufacturing 
sector and local programs promoting 
diversification is still unknown (Oregon 
Department of Human Resources 1979, 1980; 
C.C.D. Economic Improvement Assoc. 1978, 1979; 
Douglas County 1980). 



Statewide, total employment in the lumber and 
wood products sector declined at a 1.37 percent 
annual rate (Table 2-17) and total employment in 
manufacturing increased by more than 29,100 
jobs, an average annual increase of almost 2 
percent. To date, much of Oregon's diversification 
and employment growth in manufacturing has 
been in the Portland, Salem, Eugene-Springfield 
and Medford metropolitan areas. The remainder of 
western Oregon continues to be highly dependent 
on agriculture and lumber and wood products for 
significant proportions of its income and 
employment. Since southwestern Oregon is 
dominated by mountainous forest land, 
agricultural options are limited. Thus, 
overwhelmingly, the region's primary source of 
income continues to be derivatives of the timber 
resource — logs, lumber, plywood and other panel 
products, chips, pulp and paper. 



51 



Receipts from the sale or use of resources found 
on O&C, public domain and Coos Bay Wagon 
Road (CBWR) lands are distributed to State and 
local governments through distribution formulas 
established by Congress and the Oregon 
legislature. Fifty percent of the revenue from all 
O&C lands in the State is distributed among the 
counties with O&C land in proportion to the 1915 
assessed value of the O&C lands in each county. 
Tables 2-19 and 2-20 show the importance of O&C 
revenue distribution to individual counties. The 
summary data reported in Table 2-19 highlight 
principal sources of revenue (as a percent of total) 
and revenue per capita for Douglas County, all 
counties in the EIS economic region and all 
counties in Oregon. O&C revenues constitute a 
significant portion of revenue from all sources for 



Douglas, Coos, Lane, Jackson and Josephine 
counties. The resulting high level of public 
revenue per capita gives these counties 
opportunities to provide a diversity and level of 
public services more difficult to finance elsewhere 
in Oregon (Jensen 1979). The value of these 
disbursements to the O&C counties can be 
equated in terms of property tax equivalents— the 
amount per $1,000 assessed value which property 
tax levies would have to be increased to raise an 
amount of revenue equal to the county's share of 
O&C receipts. 

Payments are made to local governments from 
CBWR land revenues in the form of timber 
severance and property taxes. Severance tax 
payments are distributed to local tax districts in 



Table 2-19 County Revenue 


Sources 


as a 


Percentage of Total Revenues 


and County Revenues Per Capita for Fiscal Year 1977-78 








Douglas 


Regional Economy 


All Oregon 


Counties 


% of Total 




% of Total 




% of Total 




Source 


Revenues 


Per Capita Revenues 


Per Capita 


Revenues 


Per Capita 


I. REVENUES FROM OWN SOURCES 














Tax Revenues: 














Property Taxes 


4,2% 


$23.82 


5 2% 


S 16 27 


16.6% 


$35.76 


Other Taxes 


0,0 


.00 


0.2 


72 


1.7 


56 


Local Non-tax Revenues 














Licenses, Permits, 














Services Charges & Fees 


2.8 


15.67 


4.2 


12.94 


5 1 


1091 


Fines. Forfeitures & Court Fees 


1.3 


7.22 


1.7 


5.19 


2.0 


4.38 


Interest Earnings 


40 


2252 


4.0 


1294 


3.4 


742 


Public Service Enterprises 


1.7 


9.50 


1.1 


338 


1.9 


4.02 


Other Local Non-tax Revenues 
Subtotal: Revenues from Own Sources 


1.7 


9.38 


0.7 


2.12 


0.9 


1 99 


17.1% 


S 53 17 


31.6% 


S68 04 


II. INTERGOVERNMENTAL REVENUES 














Federal Revenues: 














General Revenue Sharing 


1,1% 


$6.14 


1 .6% 


$4 84 


3.6% 


$7.81 


Federal Land Revenue Sharing: 














National Forest Revenues 


198 


111 23 


197 


61.20 


17 4 


37.47 


O&C Revenues 


564 


317.38 


43.6 


13576 


206 


4426 


Payments in Lieu of Taxes 


0,2 


1.23 


0.2 


.61 


0.7 


1.48 


Coos Bay Wagon Rd. Revenues 


0.4 


232 


0.7 


2.04 


02 


49 


Other Land Revenue Sharing 


0.0 


.21 


0.0 


10 


0.2 


37 


Grants-ln-Aid: 














Anti-Recession Payments 


0.5 


281 


0.5 


1 61 


1 1 


245 


Countercyclical Public Works 


0,0 


00 


0.9 


2.95 


1 4 


3.07 


CETA 


0.0 


.25 


1.2 


3.72 


2.7 


583 


Other Grants-ln-Aid 


0,0 


.00 


3.2 


982 


4.1 


868 


State Revenues: 














Shared Revenues 


4 1 


22 99 


6.5 


20 19 


10.9 


2331 


Grants-ln-Aid & Others 


1.5 


8.37 


3.5 


10.92 


4 2 


9.12 


Interlocal Revenues 

Subtotal Intergovernmental Revenues 


0.4 


203 


1.3 

82 9 


420 


1.3 

68 4 


269 

03 


96 


TOTAL REVENUES FROM 














ALL SOURCES 


100% 


$56307 


100% 


$311 12 


100% 


S215.07 


Source Oregon Bureau of Governmental Research and Service. Revenue Sources 


• of Oregon Counties Fiscal Year 


1977-78. Informatation Bulletin 


No 171, Eugene. Oregon, June 1979. 















52 



Table 2-20 O&C Revenue Distribution to Counties Expressed As Property 
Tax Rate Equivalent and As Percent Supplement to Total Levy, Fiscal 
Years 1977-1980 



County 



Amount per $1,000 Assessed Value 1 

1977 1978 1979 1980 



Percent Supplement to Levy 2 

1977 1978 1979 1980 



Benton 


$3.36 


$2.26 


$2.03 


$2.05 


21.9 


12.3 


12.4 


10.5 


Clackamas 


1.69 


1.17 


1.01 


.90 


6.8 


5.4 


5.5 


46 


Columbia 


2.20 


1.77 


1.86 


1.86 


15.2 


12.7 


13.0 


11.7 


Coos 


6.59 


5.32 


4.81 


4.59 


30.9 


31.9 


29.0 


25.3 


Curry 


13.27 


9.81 


8.38 


7.09 


120.2 


102.1 


92.9 


109.2 


Douglas 


14.47 


12.44 


11.59 


11.50 


90.0 


110.3 


103.8 


79.5 


Jackson 


9.78 


6.90 


5.85 


5.51 


50.5 


39.3 


41.2 


330 


Josephine 


18.23 


11.78 


10.04 


9.56 


119.1 


74.4 


89.8 


63.0 


Klamath 


2.47 


1.85 


1.73 


1.68 


17.3 


13.4 


13.7 


11.7 


Lane 


3.92 


2.91 


2.48 


2.36 


17.1 


14.1 


13.6 


11.6 


Lincoln 


0.45 


0.40 


0.33 


0.31 


3.4 


2.5 


2.2 


1.6 


Linn 


1.77 


1.39 


1.37 


1.30 


9.4 


8.2 


8.5 


7.1 


Marion 


0.62 


0.43 


0.39 


0.36 


2.6 


2.0 


2.0 


1.7 


Multnomah 


0.13 


0.09 


0.08 


0.08 


0.5 


0.4 


0.4 


0.4 


Polk 


3.91 


2.75 


2.43 


2.41 


16.2 


13.6 


13.1 


12.2 


Tillamook 


1.38 


1.14 


1.03 


0.93 


8.2 


7.7 


6.4 


8.7 


Washington 


0.19 


0.13 


0.11 


0.10 


0.8 


0.6 


0.6 


0.5 


Yamhill 


1.09 


0.75 


0.67 


0.64 


4.9 


3.7 


3.6 


3.1 



Average 



$3.01 



$2.19 



$2.54 



$1.81 



13.6 



10.9 



10.9 



9.5 



' Represents county O&C distribution for fiscal year (ending September 30) divided by total assessed value (in thousands) on January 1 of same 

calendar year. 

2 Represents O&C distribution as percent of total property tax levy for following year, e.g., FY 1977 distribution as percent of 1977-78 levy. 

Source: USDI. BLM 1979a and 1980e. BLM Facts-Oregon and Washington, 1979, 1980; Oregon Dept of Revenue, Oregon Property Tax Statistics, 
1978; Oregon Dept. of Revenue, Dick Yates, telephone conversations, April 15, 1980, June 24. 1980; Oregon Department of Revenue, Vinh Ninh, 
telephone conversation, April 13. 1981. 



Table 2-21 In-Lieu Tax Payment on CBWR Lands Administered by the 


BLM in Douglas 


County 1 


Average Annual 




Average CBWR 
Disbursements 




Average Annual 


Property Tax 


Average Budget Levy 


(1979-1981) as a 




Severance Tax Re- 


Received 3 


Submitted By Each Tax 


Percent of Aver- 


Tax District 


ceived 2 (1979-1981) 


(1977-1981) 


District (1979-1981) 


age Levy (1979-1981) 


Douglas County 


$ 2,929 


$ 665 


$2,078,000 


0.2% 


Oakland School 










District I 


207 


68 


1,230,000 


• 0.1% 


Camas Valley School 










District 21 


9,091 


2,983 


415,000 


2.9% 


Winston Dillard School 










District 116 


23,575 


5,850 


3,018,000 


1 .0% 


Douglas Education 










Service District 


2,235 


622 


2,740,000 


0.1% 


Umpqua Community 










College 


2,295 


783 


1,951,000 


0.2% 


Roseburg School 










District 4 


4 


24 


7,949,000 


<0.1% 


' Payments in-lieu of taxes are made to the county treasurer 


and distributed to tax districts. 




2 Severance tax is 6-1/2 percent of the value of the timber harvested. 






3 Assessed value of forest land is a function of the price of second-growth Douglas- 


ir stumpage over the most recent three-year period 


4 The 27 acres of CBWR lands ir 


i this school district are not forested with commerical species. 




Source: Douglas County Assessor, Douglas County Treasu 


rer. 







53 



accordance with timber assessed values on CBWR 
lands prior to the institution of the severance tax. 
In-lieu property taxes are calculated at levy rates 
on the assessed value of land only. Table 2-21 
shows the historical distribution of these payments 
in Douglas County. 

A net of 4 percent of revenues from public domain 
lands is remitted to state governments. These 
revenues in Oregon are distributed to counties on 
the basis of total land areas for the benefit of 
county roads and bridges. Receipts from the sale 
of timber on public domain lands in the Roseburg 
District were $902,700 in FY 1980 and $461,700 in 
FY 1981. These receipts yielded $36,100 to Oregon 
counties in FY 1980 and $18,500 in FY 1981. 

Timber Industry 

Approximately one out of every four workers 
in Douglas County harvests, processes or 
transports some type of wood product (ratio of 
lumber and wood products employment to total 
employment, see Table 2-17). For the region, one 
out of every seven workers is actively engaged in 
the flow of wood products. In contrast, for all 
Oregon workers, only one in every 14 is employed 
in the wood products industry. 

During 1977-78, 40 percent of all wages paid in 
Douglas County (in sectors covered by State and 
federal employment insurance programs) 
originated in the wood products sector. For the 
region, the same figure is 27 percent and for 
Oregon, 12 percent. 

The Roseburg District plays a significant role in 
providing raw material to the lumber and wood 
products sector. For example, during the 1976- 
1977 period, 13.5 percent of the Douglas County 
harvest came from the Roseburg District (Table 2- 
22). BLM's Medford, Coos and Eugene Districts 
also administer land in Douglas County. 

Table 2-22 Timber Harvest (MM 
bd. ft. Scribner long log volume) by 
Ownership Class, Douglas County 



1976 
1977 



All 
Ownerships 

1.308.3 
1.269.1 



BLM 



3439 
2995 



Roseburg 
District 

199.7 
1476 



Source: Oregon Department of Forestry and Roseburg District 

Historical data underscore the role of BLM 
stumpage in log processing within Douglas 
County. These data show that sawmill and 
plywood and veneer facilities in the county have 
become increasingly dependent on BLM timber. 
Conversely, processors statewide are looking less 
and less to Bureau lands for log supply (Table 
2-23). 



The timber management program on the Roseburg 
District affects the regional economy employment 
and personal earnings in three ways: 1) the harvest 
and processing of the timber; 2) site preparation, 
replanting and subsequent management of 
harvested units; and 3) the disbursement of O&C 
revenues. 

The economic effects of timber harvest, 
processing, reforestation, intensive management 
and O&C disbursements to counties in the region 
stem from the average annual harvest and the 
value of the sale units harvested. During the 1976- 
1980 period, harvest of BLM timber in the 
Roseburg District averaged 187.5 MM bd. ft. and 
the typical unit yielded $157 per M bd. ft. (Table 2- 
24). This average annual harvest and value of 
receipts supported more than 3,200 jobs in the 
region, including over 2,400 jobs in Douglas 
County. The payrolls associated with this 
employment equaled $32 million in Douglas 
County and $50.1 million in the region (Table 
2-25). 

Fishing, Hunting and Other 
Recreation 

The annual economic effects of expenditures 
made by persons engaged in commercial and 
sport fishing, hunting and general recreation are 
listed in Table 2-26. In total, the production of 
these three resource categories on Roseburg 
District BLM-administered lands generates the 
equivalent of 109 full-time jobs and $568,000 in 
local personal income each year. 

Social Concerns 

Timber, as the main economic support of the 
local economy, greatly influences social attitudes 
and concerns of residents. Individual economic 
welfare is often closely related to the welfare of the 
timber industry. The current depression in the 
local economy has raised concern about the 
timber industry. 

The fluctuations of the industry have required 
people to adjust to changes in their welfare. For 
example, Figure 2-4 shows the expansions and 
contractions which took place in the lumber and 
wood products sector in Douglas County between 
1970-1980. While the average level of employment 
for the decade was 8,565, the average annual level 
of wage and salary workers ranged from a high of 
9,150 in 1973 to a low of 7,600 in 1980. 
Furthermore, forecasts of a dwindling timber 
supply (Beuter et al. 1976, Stere et al. 1980, Rahm 
1980, U.S. Forest Service 1980) in the Pacific 
Northwest and projections of declining lumber and 
wood products employment (Bruner and 
Hagenstein 1981) in one or two decades are likely 
to increase concern about the timber supply. 



54 



Table 2-23 Dependency of Log Processors in Oregon and Douglas County 
on BLM Timber (All processing estimates in M bd. ft.) 


Origin of logs consumed by sawmills in Oregon by 
1976 3 


ownership class 1968 1 , 1972 2 and 






All Ownerships 


BLM 


% BLM of Total 
Processed 


1968 
1972 
1976 


Douglas 
Douglas 
Douglas 


532,340 
632,863 
519,915 


167,408 
233,868 
222,236 


31.4 
37.0 
42.7 


1968 

1972 
1976 


Oregon 
Oregon 
Oregon 


5,863,324 
6,140,629 
5,404,346 


740,227 
801,034 
642,920 


12.6 
13.0 
11.9 


Origin of logs consumed 
and county 
1968\1972 2 and1976 3 


by plywood and veneer m 


ills in Oregon by ownership class 


1968 
1972 
1976 


Douglas 
Douglas 
Douglas 


591,560 
565,466 
599,983 


183,707 
268,500 
252,010 


31.1 
47.6 
42.0 


1968 
1972 
1976 


Oregon 
Oregon 
Oregon 


3,578,494 
3,650,016 
3,305,705 


655,670 
714,334 
584,241 


18.3 
19.6 
17.7 


1 Manack, Eugene R., Choate, Grover A., i 
State of Oregon Dept. of Forestry. 
* Schuldt, John P., and James 0. Howard, 
427, Dec. 1974, 113 p. 
Howard, James 0.. and Hiserote, Bruce 


nd Gedney. Donald R., Oregon Timber Industries: Wood Consumption and Mill Characteristics 1968. 
Oregon Forest Industries, 1972 Wood Consumption and Mill Characteristics, OSU Special Report No 
\., Oregon's Forest Products Industry 1976, USDA Forest Service Resource Bulletin PNW-79. 1978. 



Table 2-24 Harvest Sales and Receipts, BLM Timber in the Roseburg 
District (FY 1976-1980) 



Fiscal 


Sale 


Removals 


Value of Sales 


Value of Receipts 


Year 


(MM bd. ft.) 


(MM bd. ft.) 


($1,000,000) 


($1,000,000) 


1976 


232.3 


165.6 


35.0 


20.9 


Transition Quarter 


49.6 


82.8 


6.5 


13.7 


1977 


188.8 


212.2 


29.1 


39.2 


1978 


185.7 


198.3 


30.4 


27.9 


1979 


188.1 


169.9 


45.5 


27.2 


1980 


190.5 


155.4 


56.9 


26.1 



Average 12 month harvest, 1976-1980: 187.5 MM bd. ft. 
Average value per M bd. ft. removed: $157 



55 



Douglas 
County 


Regional 
Economy 


187.5 


187.5 


1,106 


1,388 


$15.8 


$20.3 


1,106 


1,331 



4,300 


4,300 


38 


38 


$0.3 


$0.3 


19 


19 



Table 2-25 Average Annual Local Economic Effects of Timber 
Management on Lands Administered by the Roseburg District (1976-1980) 

Total for 



Average Harvest Volume (MM bd. ft. Scribner Short Log Rule) 1976-1980 

Number of Local Jobs Provided by Harvesting and Processing 1 

Annual Local Payroll Generated by Harvesting and Processing ($1,000,000) 

Number of Local Jobs Produced in Other Business Sectors Resulting from 
Payrolls Created by Harvesting and Processing' 

Annual Local Payroll in Other Business Sectors Created by Harvesting and $10.4 $13.8 

Processing ($1,000,000) 2 

Acres Harvested Each Year 

Number of Local Jobs in Reforestation and Intensive Management 1 

Annual Local Payroll in Reforestation and Intensive Management ($1,000,000) 2 

Number of Local Jobs Produced in Other Business Sectors Because of 
Reforestation and Intensive Management on Lands Administered by the Roseburg 
District 1 

Annual Local Payroll Produced in Other Business Sectors Because of $ 0.1 $ 0.1 

Reforestation and Intensive Management on Lands Administered by the Roseburg 
District ($1,000,000) 2 

Public Revenue to County Governments Attributable to the Harvest ($1,000,000 $ 3.7 $10.9 

in O&C Disbursements) 

Number of Employees of County Government Whose Jobs Depend Upon Public 73 214 

Revenues from the Sale of BLM Timber Obtained from Lands Administered by the 
Roseburg District 

Annual Payroll of County Government Employees Whose Jobs Depend Upon $0.8 $2.2 

Public Revenue from the Sale of BLM Timber Obtained from Lands Administered 
by the Roseburg District ($1,000,000) 2 

Number of Local Jobs Produced in Other Business Sectors Because of County 79 232 

Employment Dependent on O&C Disbursements and the Jobs Created by 
Disbursements Passed Through to the Local Economy in the Form of Capital 
Construction or County Support of Local Programs 

Annual Payrolls in Other Business Sectors Dependent on County Payrolls $0.9 $2.5 

Created By Disbursements Passed Through to the Local Economy in the Form of 
Capital Construction or County Support of Local Programs ($1,000,000) 2 

Total Local Employment Effect of the Timber Management Program 1 

Local employment effect per MM bd. ft. of BLM timber harvested 

Local earnings per MM bd. ft of BLM timber harvested 

Total Local Payroll Effect of the Timber Management Program 
($1,000,000) 2 

' All estimates refer to full-time employment, e.g., two jobs of 6-month duration equal one full-time equivalent. 
•'1976- 1978 dollars. 



2,421 


3,222 


12.9 


17.2 


$150,900 


$209,100 


$28.3 


$39.2 



56 



Table 2-26 Local Economic Effects 
of Fisheries, Terrestrial Wildlife and 
General Recreation 




Employment 


Earnings' 


Fisheries 

Direct 
Indirect 


25 
10 


130.000 
76,000 


Hunting 

Direct 
Indirect 


15 
6 


64,000 
36,000 


Other Recreation 

Direct 
Indirect 


38 
15 


163,000 
99,000 


Total 


109 


568,000 


1 1976-1978 dollars 







The seasonal variations in timber industry and the 
longer fluctuations in employment attributable to 
market conditions have produced a kind of dual 
work force in the industry consisting of a core of 
stable, senior workers and a peripheral group of 
workers who "float" in and out of the industry in 
response to the job situation or higher pay 
(Stevens 1978). 

Herbicide use is a controversial issue having many 
vocal advocates and opponents. Advocates believe 
it is an inexpensive and safe means of increasing 
timber production by controlling competing 
vegetation when used with proper safeguards. 
Opponents believe further evidence is needed to 
prove that herbicide use is less expensive than 
other means. They also believe herbicide use may 
be damaging to the environment and harmful to 
human health. 

Also controversial with some adjoining landowners 
and other residents are clearcutting and 
anticipated damage to watersheds from harvesting 
timber on steep slopes. 



FIGURE 2-4 



CO 

UJ 

LlJ 

>- 

o 



Annual Average Lumber and Wood Products Employment 
Douglas County, Oregon 1 970 -1 980 



10,000 



9000 



8000 




£ 7000 
rr 

UJ 
GO 

2 6000 

3 







1970 



71 



72 



73 



74 



75 76 

YEAR 



77 



78 



79 



80 



57 



Table 2-27 Changes Desired by Survey Respondents in the Use of Federal 

Lands 

(Percent distribution omitting undecided respondents) 



Oregon 



Southern Oregon 







No 






No 




Use 


More 


Change 


Less 


More 


Change 


Less 


Wildlife habitat 


61 


30 


8 


49 


36 


14 


Hiking/Camping 


52 


38 


8 


40 


46 


12 


Wilderness 


44 


38 


16 


32 


28 


39 


ORVs/snowmobiles 


13 


24 


60 


19 


33 


44 


Timber Production 


41 


38 


19 


60 


26 


13 


Hunting/Fishing 


51 


40 


7 


53 


42 


4 



Source: Tiff Harris, Public Perceptions of Federal Land Use Decisionmaking in Oregon: Results of a State-wide Survey, Oregon State University. 
August 1979 

A recent statewide survey by Bardsley and 
Haslacher (Harris 1979) showed that residents of 
southern Oregon (including Douglas County) have 
different attitudes about the use of federal lands 
than do Oregonians in general. These survey 
results are shown in Table 2-27. 

Local Employment and 
Personal Earnings Attributable 
to Resources Produced by 
BLM-Administered Land 

In summary, the principal sources of local 
employment and personal earnings attributable to 
resources produced on BLM-administered land in 
the Roseburg District are: 

Resource Employment Earnings 

Timber 3,222 $39,200,000 

Commercial and Sport 
Fisheries 

Hunting 

Other Recreation 



35 



206,000 



21 100,000 

53 262,000 

3,331 $39,768,000 



59 



Chapter 3 Environmental 
Consequences 



Introduction 







In this chapter, environmental consequences 
(impacts) are compared to the existing situation, 
as described in Chapter 2. Economic impacts are 
based on the existing situation plus projections of 
price and revenue levels under Alternative 5 (No 
Action). The significant impacts resulting from 
implementation of each of the alternatives are 
analyzed in relation to these baselines. A tabular 
comparison of composite impacts from each 
alternative is shown in Table 1-5. Analysis, 
including the scoping process, indicates that 
timber management would have no significant 
impacts upon climate, geology, topography, 
minerals, grazing, agriculture, utilities, 
communication sites and wilderness. Therefore, 
these topics are not discussed. 

The major actions which cause impacts are timber 
harvest, road construction, site preparation 
(includes slash burning and herbicide use), 
plantation maintenance and release, plantation 
protection, precommercial thinning and 
fertilization. Significant effects to the local area 
and its economic base can also occur, depending 
upon which alternative and harvest volume levels 
are ultimately selected. These would include 
changes in employment, personal income and 
sharing of sale receipts with county governments, 
school districts and other local taxing entities. 



60 



In analyzing the impacts of the Original Proposed 
Action (Alternative 4), a sample 5-year (1984-1988) 
timber sale plan (available for review at the 
Roseburg District Office) was developed and used, 
where applicable, to assess potential site specific 
timber sale impacts. Although a 5-year plan is 
used for analysis purposes, actions identified are 
considered typical for the entire decade. Possible 
conflicts identified in this chapter for specific sales 
will be thoroughly addressed in detailed site 
specific environmental assessments. Timber 
management treatments not included in the timber 
sale plan (planting, vegetation control with 
herbicides, animal damage control, precommercial 
thinning and fertilization) are analyzed at the 
proposed 10-year levels. Site specific 
environmental assessments will be prepared when 
specific acreages are identified for each treatment. 
Analysis of the alternatives is based on the 
different levels of treatments shown in Table 1-2. 

Two time frames are used in the analysis process. 
The short term is the first 10 years following the 
adoption of a new timber management plan. The 
long term is defined as beyond 10 years. Other 
time periods pertinent to specific impact 
discussions are used as necessary and identified 
in the text. 

Analysis of long-term impacts for all alternatives is 
based on the assumption that the alternatives 
would be continued for many decades. In fact, the 
10-year timber management plan and related land- 
use allocations selected after completion of the 
EIS will be subject to revision at the end of one 
decade. 

A basic assumption of the analysis is that 
sufficient funding and personnel will be available 
for implementation of the final decision. 

Impacts on Air Quality 

During the construction of new roads and 
maintenance of older roads, fine particulate matter 
would be disturbed. This dust settles back to earth 
in relatively short distances, does not adversely 
impact anyone away from the construction sites 
and thus will not be considered further. 

The major impact to air quality in the SYUs would 
be from slash burning. Estimated levels of burning 
activity by alternative are given in Table 1-2 (Site 
Preparation/Broadcast Burning). 

Regardless of the alternative selected, all burning 
would be done in accordance with the Oregon 
Smoke Management Plan. Normally, smoke would 
be carried into upper air levels and away from 
populated areas. Occasionally, unforecasted 
weather changes could cause some smoke to 
return to surface areas, causing visible intrusions 
in nearby residential areas. When slash fires are 
allowed to burn or smolder overnight, the cooling 
nighttime temperatures bring residual smoke down 



valleys, causing problems with visibility and 
increased particulates. The probability of intrusion 
would be highest under Alternative 1, due to more 
acres burned, and lowest under Alternative 8. Past 
experience indicates that visible intrusions may 
affect the population centers of Eugene- 
Springfield and Roseburg. Reported smoke 
intrusions from BLM Roseburg District slash burns 
affected the area from Roseburg to North Bend in 
1980 (OSDF 1981). Between 1976 and 1981 
Roseburg BLM was responsible for 18 of the 56 (32 
percent) reported smoke intrusions in Douglas 
County. None of the intrusions during the above 
period led to a violation of primary air quality 
standards for total suspended particulates (Table 
2-1). 

Since 1980, there has been an effort to shift the 
prescribed fire workload from the traditional fall 
season to spring and early summer. It is estimated 
that 30 percent of the prescribed fire workload will 
occur in the spring and early summer. This is the 
season of best smoke dispersion opportunities. In 
the spring, larger fuels and the duff have fuel 
moistures too high to sustain fire. This results in 
less volume consumed and a corresponding 
reduced volume of smoke. Climatic conditions in 
the spring also increase the efficiencies of 
prescribed fire mop-up activities, resulting in less 
residual smoke. The trend in increasing wood 
utilization is also contributing to less volumes of 
slash occurring on harvested areas. These 
emission reduction techniques contribute to an 
estimated 35 percent decrease in volume of smoke 
produced per acre burned (Sandberg 1983). This 
data does not allow a statistically correct 
projection of expected problems over the next 
decade. 

Airborne particles less than 1.0 micron in diameter 
make up 80 percent of smoke particulates. 
Particles of this size have very low fall velocities, 
about 5 cm/hour, and therefore will travel 
distances of approximately 100 miles. Particles of 
this size also scatter visible light (0.3 microns blue 
to 0.8 microns red), causing visibility problems. 

Depending on the wind direction and speed 
following slash fires, visibility intrusions could 
occur in the Eugene-Springfield AQMA, the 
Roseburg AQMA, and in the following Class I 
areas: Kalmiopsis, Crater Lake, Mt. Washington, 
Three Sisters, Mt. Jefferson and Diamond Peak. 

The wood component of slash is made up of about 
50 percent carbon, 6 percent hydrogen, 43 percent 
oxygen and small amounts of nitrogen and other 
elements. When burning occurs, temperatures of 
570° F to 2550° are maintained (Hall 1972) which 
produce carbon dioxide and water vapor. The 
whitish column of smoke observed from controlled 
slash fires is made up of over 90 percent water 
vapor and C0 2 (Table 3-1 ). 



61 



Table 3-1 Avi 



verage Emission Components From Slash Burning (Tons/Decade) 



ALTERNATIV 





1 


2 


3 


4 


5 


6 


7 


8 


9 




Max. Tbr. 


Emp. Tbr. 


LoMHS 


OPA 


No Action 


HD 


No Herb. 


Full Eco. 


NPA 


Tons of Slash 


182,308 


167,654 


161,487 


157,105 


120,922 


115,472 


108,269 


54,369 


155,826 


Burned 




















Particulates' 


3.828 


3,521 


3,391 


3,299 


2,539 


2,425 


2,274 


1,142 


3,273 


Hydrocarbons 


2,279 


2,096 


2,019 


1,964 


1,512 


1,443 


1,353 


680 


1.948 


Carbon Monoxide' 


23,700 


21,795 


20,993 


20,424 


15,720 


15,011 


14,075 


7,068 


20,262 


Sulfur Oxides 4 








Negl 


igible 










Nitrous Oxides 5 


365 


335 


323 


314 


242 


231 


217 


109 


312 


Water Vapor and 




















Carbon Dioxide 6 






90% 


of the Mass of Combustion Products - 









' Particulates are near 0.1 micrometer in diameter. Average emission of 17-67 pounds/ton slash burned. 

2 Hydrocarbons are a diverse class of compounds containing hydrogen, carbon and oxygen. 

3 Carbon monoxide (CO) is very short lived in the natural environment and quickly dilutes and also converts to C0 2 . 

4 Sulfur oxides (SOx) are produced in small quantities, since most forest residues contain less than 0.2 percent sulfur 

5 Nitrogen oxides (NOx) are found in some very hot fires, but this is generally not a problem in prescribed burns. The temperature 
required to fix atmospheric nitrogen is over 2800° F and such a temperature is not frequently attained in slash burns. 

6 Carbon Dioxide (CO,) is not an air pollutant in the usual sense. About 1 ton of burned fuel produces 1 to 1-1/2 tons of C0 2 (Ryan et 
al. 1976, cited in Sandberg et al. 1978). 



Source: J Alfred Hall 1972 and Sandberg et al. 1978 

The contaminants most frequently found in slash 
smoke are carbon dioxide (C0 2 ), carbon monoxide 
(CO), nitrogen oxides (NO x ), hydrocarbons (HC) 
and respirable fine particulates (Sandberg et al. 
1978). 

Conclusions 

The major impact to air quality would be 
visible smoke from slash burning. Although 
occasional smoke intrusions are likely, none are 
expected to violate primary air quality standards 
for total suspended particulates. 

Impacts on Soils 

The major impacts of timber management on 
soils are compaction, landsliding, topsoil erosion 
and depletion of organic matter, nitrogen and 
other nutrients. Each results in a loss of soil 
productivity (see Glossary). Timber management 
activities that are the causal agents include road, 
fire trail and landing construction; yarding logs; 
scarification and slash burning. The amount of 
landslides and surface erosion is influenced by the 
steepness of slopes, soil properties, amount of 
disturbance and remaining litter cover, and the 
amount and intensity of precipitation (Pritchett 
1979). 

Standard design features would be employed to 
minimize adverse impacts on soils. Compacted 
soils from tractor logging in clearcut units would 
be ripped or tilled to partially restore productivity. 
Loss of productivity due to compaction from 
tractor logging in partial cut units cannot be 
mitigated during the rest of the rotation. Partial 
and total suspension yarding systems would be 
used to minimize soil disturbance. New roads 
would be located away from streams and on 



ridgetops and designed to avoid undercutting or 
overloading unstable slopes. Excess road material 
on unstable and potentially unstable slopes would 
be end-hauled to reduce landsliding. Scarification 
would be done during dry soil conditions without 
piling soil. Slash burning and scarification would 
be minimized on thin, droughty or nitrogen- 
deficient soils. 

Table 3-2 shows estimated acres upon which soil 
productivity would be lost as a result of timber 
management under the proposed action and 
alternatives during the first decade. 

Soil compaction results primarily from the weight 
and shearing forces involved in dragging logs and 
operating ground-based logging equipment. 
Compaction hinders root penetration and water 
percolation and availability, reducing vegetation 
growth. Decreases in root penetration of 35 to 65 
percent can reduce the vegetative productivity of 
soils by 10 to 25 percent (Power 1981a). In the 
Roseburg SYUs, tractor logging has been found to 
reduce soil productivity for the entire cutting unit 
by 11.8 percent due to compaction (Wert and 
Thomas 1981). Yarding systems using ground- 
based equipment have a greater adverse impact on 
soils than cable systems which drag the logs. One 
end suspension has a lesser impact than systems 
providing no suspension. Systems using total 
suspension have the least impact on soils. 
Compaction and reduced infiltration capacity have 
been found to last at least 55 years (Power 1974, 
cited in Fredriksen and Harr 1979) and therefore 
may last longer than harvest rotation periods. 

Site scarification and slash piling by tractors with 
brush rakes compacts soils and displaces topsoil. 
This practice can be expected to reduce soil 



62 



Table 3-2 Estimated Loss of Productivity During First Decade (acres) 1 



Process 

Road 
Construction 2 

Yarding Systems 
(Compaction) 3 

Landsliding from 
Fragile Soils 

Dry Ravelling 

Nutrient Depletion 

Totals 



Alt. 1 Alt. 2 Alt. 3 Alt. 4 Alt. 5 Alt. 6 Alt. 7 Alt. 8 Alt. 9 

Max. Emp. Lo No No Full 

Tbr. Tbr. MHS OPA Action HD Herb. Eco. NPA 



5,568 5,124 4,932 4,800 3,696 3,528 3,306 1,662 4,780 



3,551 3,267 3,135 3,057 3,132 2,250 2,131 980 3,056 



11 



10 



17 16 15 15 

Acreage data unavailable 
Acreage data unavailable (see Table 3-3) 
9,136 8,407 8,082 7,872 6,839 5,788 



10 



15 



5,447 2,647 7,851 



' Productivity loss of commercial timber resulting from road construction and landslides is long term. Loss from compaction has been 
estimated to last up to 55 years on some soils. 

2 From Table 1-2. 

3 These are equivalent net acres (acres compacted x percent loss of productivity due to compaction) assuming amelioration by 
ripping. 



productivity by 11 to 22 percent (Clutter and Dell 
1978). One study in the Salem District showed a 
reduction of 17 percent in productivity after 
scarification (Power 1981b). Topsoil is also 
removed by dragging logs and by constructing fire 
trails, roads and landings with heavy equipment. 
On clearcuts yarded by tractors, predesignated 
skid roads will be used so that less than 10 percent 
of the surface area will be traversed. 

On very steep slopes with decomposing granitic 
bedrock, clearcutting increases the number and 
magnitude of debris avalanches and torrents. This 
increase is caused by decay of small tree roots, log 
gouges from yarding, plugged road culverts and 
road construction and usually occurs 1 to 3 years 
after harvesting (Hughes and Edwards 1978). The 
5-year timber sale plan shows 825 acres of soils 
from granitics would be subjected to timber 
harvest. 

Erosion from landslides in Tyee sandstone, as 
measured in the Mapleton Ranger District 
(Swanson, Swanson and Woods 1977), increases 
123 times above the undisturbed forest rate 
following clearcutting and roadbuilding. 
Approximately 4,600 acres of these soils, identified 
as fragile, would be harvested as shown in the 
sample 5-year timber sale plan. 

Estimates of acres of soil lost due to landsliding 
are given in Table 3-2. The size of potential 
landslides ranges from 20 to 250 feet wide and 200 
to 6,000 feet long. Material from such slope 
failures usually scour stream channels to bedrock, 
ending in debris dams. 



Dry ravelling in disturbed areas takes place 
throughout the year in the SYUs and results in loss 
of topsoil and decreased soil depth. When 
vegetation and duff are removed by yarding logs, 
slash burning or other practices, surface soil is 
free to move and ravelling is accelerated. On 
steep, south-facing slopes ravelling may continue 
for 20 to 30 years after disturbance or until 
vegetation becomes reestablished. 

Nitrogen (N) in forest soils is largely in the humus 
layer. Amounts of 2 to 10 tons per acre can be 
found in deep silt loams under old growth 
Douglas-fir (Heilman 1981). Much of this N in the 
slash and litter is volatilized during slash burning 
and is lost. Total loss of N from clearcutting and 
slash burning can reach as high as 9 percent of 
available N (Hornbeck et al. 1974, in Sopper 1975), 
but more likely will be about 4 percent (Grier 
1982). Losses of phosphorus (P) are similar to 

Table 3-3 Expected Nutrient Losses 
(Tons) from Timber Harvesting and 
Slash Burning (10-Year Plan) 



Alternative 


N 


P 


K 


Ca 


1 (Max Tbr ) 


3.076 


3.691 


344 


850 


? (Emp Tbr) 


2,829 


3,394 


316 


782 


3 (Lo MHS) 


2.725 


3.269 


305 


753 


4 (OPA) 


2.651 


3.181 


296 


733 


5 (No Action) 


2.040 


2 448 


228 


564 


6(HD) 


1.949 


2.338 


218 


538 


7 (No Herb ) 


1.827 


2.192 


204 


505 


Eco.) 


917 


1.101 


103 


254 


9 (NPA) 


2,640 


3.170 


295 


731 



Source: Based on analysis of a 35-year-old. second growth 
Douglas-fir ecosystem. 



63 



losses of N. Losses of nutrients calcium (Ca) and 
potassium (K) are a little less than N and P 
(Fredriksen 1972; Grier, personal communication). 
These nutrients are attached to organic detritus 
and soil particles and are lost as the soil erodes. 
Assuming a 4 percent loss of N and P, and a 3 
percent loss of Ca and K following clearcutting 
and burning (site preparation), each alternative 
would result in losses shown in Table 3-3. 

Conclusions 

Impacts to soil and soil productivity are 
mainly due to road construction, landslides, and 
compaction. Alternative 1 has the greatest impacts 
on long- and short-term soil productivity while 
Alternative 8 has the least. Acres lost from 
production range from 2,647 under Alternative 8 to 
9,136 under Alternative 1. Less signifcant impacts 
include nutrient losses, dry ravelling, and topsoil 
removal. 

Impacts on Water 
Resources 

Forest management activities which would 
impact water resources include road building, 
timber harvest, slash burning and application of 
fertilizers and herbicides. These activities can 
affect water yields, seasonal streamflow 
characteristics (peaks and low flows) and instream 
water quality (sedimentation, temperature, 
dissolved oxygen, nutrients and organic 
substances). The significance of each impact 
would depend upon the amount of timber 
harvested in each watershed, the proximity of the 
activities to streams and the site specific 
application of mitigating measures. 



Water Quantity 



Forest harvest activities would have very 
little effect on the streamflow of larger rivers 
draining the SYUs. Table 3-4 shows estimates of 
annual water yield from public lands in the SYUs 
for each alternative, compared to the existing yield 
and undisturbed watershed. 

Although the effect of timber harvest on 
streamflow in the larger rivers would be small, 
local increases in water yield would occur in 
clearcut areas. Removing forest vegetation 
reduces evapo-transpiration (see Glossary), 
thereby increasing the amount of rainfall available 
for streamflow. Studies of clearcutting small 
watersheds in western Oregon showed that water 
yields from clearcut areas increased 26 to 43 
percent following harvest (Harris 1977; Rothacher 
1970; Harr et al. 1979). Based on Rothacher's 
(1970) study of clearcutting in the central Oregon 
Cascades, water yield from clearcut areas in the 
SYUs is expected to increase 35 percent. The 
duration of increased water yields is not easily 
predicted; however, varying degrees of altered 
yields may last up to 35 years (Kovner 1956, cited 



Table 3-4 


Estimated 


Annual Water 


Yield From BLM- Administered Land, 


End of First Decade 










Percent 


Percent 




Annual 


Change 


Change 




Water Yield 


From 


From 


Situation 


(acre-feet) 


Existing 


Undisturbed 


Past Decade 


863,000 





44 


Alt. 1 (Max. Tbr.) 


879.000 


1.8 


63 


Alt. 2 (Emp. Tbr.) 


875.000 


1.3 


5.8 


Alt. 3(LoMHS) 


873.000 


1.1 


56 


Alt. 4 (OPA) 


872,000 


1.0 


5.4 


Alt. 5 (No Action) 


864,000 


0.1 


46 


Alt. 6(HD) 


860,000 


-0.4 


4.0 


Alt. 7 (No Herb.) 


858,000 


-0.6 


38 


Alt. 8 (Full Eco.) 


841.000 


-2.5 


1.8 


Alt. 9 (NPA) 


871.000 


0.9 


5.3 


Source: Based on 


analysis of a 35 


-year-old, 


second growth 


Douglas-fir ecosystem. 







in Harr et al. 1979). Compacted soils and roads 
which increase surface water runoff are permanent 
sources of water yield increases. 

In addition to altering total annual water yields, 
timber harvest would affect the timing and 
magnitude of seasonal streamflows in small 
watersheds in the SYUs. Rothacher's (1970, 1973) 
study of small watersheds near the SYUs showed 
fall and spring peak flows were increased by 
logging, although extreme winter peaks were 
relatively unaffected. A recent analysis (Christener 
1981) suggests that extreme winter peaks may also 
be increased by timber harvest if the peaks occur 
from heavy rainfall on an existing snowpack. 
Summer low flow levels would also be increased 
by timber harvest. Studies of other small 
watersheds in the central Oregon Cascades 
(Rothacher 1971) suggest minimum flows for small 
watersheds in the SYUs would increase up to 300 
percent. Although relative changes in minimum 
flows may be large (200 to 300 percent), absolute 
changes would be small, due to naturally low 
levels of streamflow during the summer months 
(ibid.). Increases in peaks and low flows would be 
greatest in small watersheds sustaining the 
greatest increases in clearcut acreages during the 
next decade. 



Water Quality 



Timber harvesting, road building and slash 
burning would increase sediment discharge from 
affected small watersheds in the SYUs. Fredriksen 
and Harr (1979) reported that logging in the 
central Oregon Cascades increased suspended 
sediment yield 23 times the natural rate 
(undisturbed condition) in a patch cut watershed 
with roads, and nine times the natural rate in a 
clearcut watershed without roads. Hughes and 
Edwards (1978) reported that sluice-outs from 
intermittent streams in clearcuts were eight times 
as large (on a per acre basis) as from intermittent 
streams in undisturbed watersheds, and most (85 



64 



percent) resulted from headwall failure. These 
sluice-outs originated in granitic soils (Holland- 
Siskiyou series) during storms of 5 to 12 year 
return periods (see Impacts on Soils). Clearcut 
acres produced about 530 tons/acre of sediment 
from landslides in granitic soils. Similar increases 
in sediment yield can be expected in small 
watersheds within the SYUs where mass soil 
movement (debris avalanching) is the dominant 
erosion process (see Impacts on Soils). In 
undisturbed watersheds, streams are usually 
capable of transporting more sediment than is 
delivered to them (Rice et al. 1979). During and 
following timber harvest, road construction and 
slash burning, sediment and debris would be 
delivered to drainage systems. Sediment discharge 
would then no longer be determined by the 
availability of sediments, but by the transporting 
ability of streams. Increased water yields (Table 3- 
4) would also increase the ability of streams to 
transport sediments. Where stream energy is 
insufficient to transport all the sediment, 
deposition would occur. 

Surface vegetation left undisturbed in areas 
bordering streams can act as a filter and retain soil 
particles eroded from the surface of disturbed 
areas, thereby reducing suspended sediments in 
streams. The effectiveness of sediment buffers is 
dependent upon slope, type and density of 
vegetation and buffer width. When water 
temperature is not a concern and careful planning 
is used in partial cutting of buffers (falling timber 
away from streams, no tractor harvest and no 
burning), the removal of merchantable timber may 
not adversely affect the sediment trapping ability 
of the buffer (Froehlich 1982). Buffers would 
protect third order and larger streams in 
Alternatives 2 through 7 and 9, and protect all 
streams in Alternative 8. In Alternative 1 no harvest 
restrictions are planned for stream buffers except 
as provided by the Oregon Forest Practices Act. 
When buffers are left on third order and larger 
streams, only sediment produced from first and 
second order streams will enter at the headwaters 
and be carried down the drainage system 
whenever stream energy is sufficient for transport. 

Sediment yield from surface erosion and runoff 
was estimated by examining the number of acres 
of buffers harvested in each alternative and is 
displayed in Table 3-5. The percent of the buffers 
to be cut was used to estimate sediment yield 
(Table 3-6) and altered water temperatures. 

Estimates of total sediment yield are presented in 
Table 3-6. 



Table 3-5 Estimated Sediment Yield 
Through Buffer Strips 
(For First Decade) 





Acres of 


Proposed 


Tons of Sediment 




Buffers to be 


From Sheet 


Alternative 


Harvested 


Erosion 




Clearcut 


Partial cut 




1 (Max. Tbr.) 


N/A' 


N/A' 


303,000 


2 (Emp. Tbr.) 


127 


1,018 


176.800 


3 (LoMHS) 


121 


981 


153,800 


4 (OPA) 


120 


960 


148,900 


5 (No Action) 


40 


310 


164,600 


6 (HD) 











7 (No Herb.) 


8 


660 


102,900 


8 (Full Eco.) 











9(NPA) 












1 No harvest restrictions are planned. 

The chemical quality of surface water would be 
affected by slash disposal. In one Oregon 
Cascades watershed studied by Fredriksen (1971), 
instream concentrations of ammonia-nitrogen and 
manganese reached peak levels of 7.6 and 0.44 
parts per million (ppm), respectively, when runoff 
from rainfall that extingushed the burn entered the 
stream. In the SYUs, only Alternative 8 would 
provide adequate protection for streams. 
Ammonia-nitrogen and manganese concentrations 
could exceed recommended water quality 
standards (0.02 ppm for free ammonia-nitrogen, 
0.05 for manganese) in some first and second 
order streams for several days following slash 
burning. However, water from these streams would 
quickly be diluted upon entering third order or 
larger streams, resulting in a slight, short-term 
impact. 

Due to insignificant surface runoff in areas to be 
fertilized, substantial increases in nutrient 
concentrations following forest fertilization are not 
expected in the SYUs. Pelleted urea dissolves 
slowly and is utilized by vegetation before it can be 
translocated. 

Timber harvest affects stream temperatures by 
removing shading vegetation from streambanks. 
Stream temperature increases of 10 F or more 
have been recorded following removal of 
streamside vegetation by clearcutting and burning 
in both the Oregon Cascades and Coast Range 
(Brown and Krygier 1970; Levno and Rothacher 
1969). Alternative 8 provides temperature 
maintenance for first order and larger streams. 
Under Alternative 1, removal of merchantable 
timber (see Table 3-5) would reduce the 
effectiveness of buffers to provide adequate shade, 
resulting in increased temperatures. Downstream 
shading does not significantly lower temperatures 
of streams warmed by upstream exposure (Brown 
etal. 1971). 



65 



Table 3-6 Estimated Sediment Yield From BLM-Administered Land, 


First Decade 










(Tons/Decade) 


From 


From 






Alternative 


Landslides 


Sheet Erosion 


From Roads 


Total 


1 (Max. Tbr.) 


84,100 


303,000 


104,400 


491,500 


2 (Emp. Tbr.) 


77,300 


176,800 


61,000 


315,100 


3 (Lo MHS) 


74,500 


153,800 


53,000 


281,300 


4 (OPA) 


72,500 


148,900 


51,400 


272,800 


5 (No Action) 


55,800 


164,600 


56,800 


277,200 


6(HD) 


53,300 





46,000 


99,300 


7 (No Herb.) 


49,900 


102,900 


35,500 


188,300 


8 (Full Eco.) 


25,100 





17,800 


42,900 


9 (NPA) 


72,300 





51,200 


123,500 



Harvest activities may reduce instream 
concentrations of dissolved oxygen by adding 
debris to streams. Fine organic debris (such as 
small twigs and needles) uses dissolved oxygen 
during decomposition. This depletes dissolved 
oxygen concentrations at times of high stream 
temperatures, low streamflows and low available 
oxygen. Since instream oxygen concentrations 
quickly return to normal following stream cleanout 
and fall rains (Hall and Lantz 1969), low instream 
oxygen concentrations would only be local and 
temporary in the SYUs. However, oxygen 
concentrations in stream gravel may continue to 
decline for several years after logging, because 
waterflow through gravels is restricted by 
sedimentation (Hall and Lantz 1969). For this 
reason, impacts on intragravel oxygen in the SYUs 
would be directly related to the changes in 
sediment yield discussed above. 

The effects of herbicide application on water 
quality have been described elsewhere (USDI, 
BLM 1978). Design elements (see Chapter 1) such 
as buffer strips are expected to minimize herbicide 
drift or accidental direct spraying of water bodies. 
Amounts of herbicide reaching streams beyond 
these barriers would be insignificant and would 
not adversely affect water quality. Movement of 
herbicides through the soil (leaching) is usually 
measured in terms of inches or a few feet (Norris 
1975). This is a slow process that would not lead to 
stream contamination, because the herbicide 
would degrade before reaching free water (ibid.). 
For additional discussion, see Chapter 3, Impacts 
on Animals and Impacts on Human Health. 

Municipal Watersheds 

The cities of Riddle, Canyonville and Drain 
have signed Memoranda of Understanding (MOU) 
which outline practices to be utilized in the 
municipal watersheds. The sample 5-year timber 
sale plan water yield (see discussion of altered 
water yields, this section) and increased 
sedimentation. Although an increase in water yield 



may be beneficial, the increase in suspended 
solids would result in increased filtration costs. 

Conclusions 

Timber harvest would have very little effect 
on water yield in the larger rivers and streams. 
Sedimentation is expected to be greatest under 
Alternative 1 and least under Alternative 8. 
Increased stream temperatures can be expected in 
Alternative 1. There would be 469 acres harvested 
in municipal watersheds in 5 years. Overall 
impacts are greatest in Alternative 1 and least in 
Alternative 8. 

Impacts on Vegetation 

This section describes the impacts of 
implementing a timber management plan on 
vegetation. All impacts to wetland and aquatic 
vegetation 3-7 shows the are expected to be 
insignificant potential activity in those watersheds. 



Table 3-7 Proposed Activities in 
Municipal Watersheds Based on 
the Sample Five-Year Timber Sale 
Plan 







Acres to be 


Municipal Watershed 


Sale Year 


Harvested* 


City of Canyonville 


1985 


118 


City of Drain 


1985 


160 


City of Riddle 


1987 


133 


City of Riddle 


1988 


58 



Similar harvests have occurred in each of these watersheds over 
the past decade 



66 

The impacts of timber harvesting on municipal 
watersheds would be increased for all alternatives 
except 1. Under Alternative 1, wetlands would be 
significantly impacted by harvesting operations. 
Aquatic vegetation would be protected only to the 
degree afforded streams under the Oregon Forest 
Practices Act. This would be inconsistent with 
Executive Orders 11988 and 11990. 

Terrestrial Vegetation 

Management treatments applied under each 
alternative would impact the existing vegetation in 
direct relation to the level of treatment shown in 
Table 1-2. Impacts to riparian habitat are expected 
to be insignificant under Alternatives 6, 8 and 9 
(over 18,300 acres protected). However, under 
Alternative 1", riparian habitat would be included in 
adjacent areas scheduled for final harvest and 
subsequent management treatments. Under 
Alternatives 2, 3, 4 and 7, the modified area control 
concept would provide for harvest in riparian areas 
(along third order and larger streams) by 
individual tree selection, shelterwood or clearcut 
methods. Alternative 5 would provide protection 
for 8,070 acres along third order and larger 
streams. Areas adjacent to first and second order 
streams would be harvested under all alternatives 
except 8 (see Table C-4). The resulting impact 
would be alteration of the riparian habitat in and 
around those areas where harvesting operations 
would occur. The degree of impact would range 
from removal of the old growth component where 
individual trees are removed to severe alterations 
where clearcutting occurs. 

Timber harvesting initiates plant succession by 
creating openings in the forest canopy similar to 



those created by natural disturbances. Different 
cutting practices (i.e., clearcutting and single tree 
selection methods) open the canopy to varying 
degrees, thereby influencing the plant composition 
and duration of the plant communities. 

Clearcutting completely removes the forest 
canopy, thereby allowing the establishment of the 
first successional stage (grass/forb). Openings in 
the canopy created by commercial thinning, and to 
a lesser extent mortality salvage, could result in 
insignificant growth increases of understory 
vegetation. 

Vegetation composition in the SYUs would change 
according to the level of harvest proposed under 
each alternative. When compared to the existing 
forest profile, this change is notable by a shift of 
acreage from one age class to another (i.e., old 
growth to non-stocked or 0-7 year age group). 
This acreage shift is best shown by a percent 
change in individual age class stratification as 
shown in Table 3-8. Long-term effects (first, 
second, fifth and tenth decades) were projected 
and are displayed in Appendices E and F. 

The full scope of potential benefits that might 
accrue from old growth retention is yet unknown. 
Maintaining a representative structural component 
of old growth Douglas-fir across a range of 
environmental variables until these processes are 
better understood may be essential to maintaining 
the long-term productivity of timber stands. 

Yarding practices to be employed during the 10- 
year period consist of ground or partial 
suspension cable systems, cable with full 
suspension and tractor systems. Each system 



Table 3-8 Approximate Acres of BLM-Administered Timber Lands and Percent 
of Change after One Decade 



Habitat Age 


Current 
Acres 


Alt. 1 
Max. Tbr. 


Alt. 2 
Emp. Tbr. 


Alt. 3 
Lo MHS 


Alt. 4 
OPA 


Alt. 5 

No 
Action 


Alt. 6 
HD 


Alt. 7 
No Herb. 


Alt. 8 
Full Eco. 


Alt. 9 
NPA 


Grass/Forb 
Non-stocked and 
0-7 Years 


34,143 


54,957 
+61% 


50.359 
+47% 


48,293 

+ 41% 


46,930 
37% 


29,164 
-15% 


34,066 
<-1% 


32.163 
-6% 


15.212 
-55% 


46.741 

+ 37% 


Brush/Seedling 
8-15 Years 


40,853 


42,399 

+ 4% 


41,636 
+2% 


41,446 
+ 1% 


41,205 
+ 1% 


42,621 
+ 4% 


39.204 
-4% 


38,773 
-5% 


36,421 
-11% 


41,100 

< 1 % 


Pole Sapling 
16-45 Years 


56,393 


91.329 
+62% 


91.329 

+62% 


91,329 
+ 62% 


91,329 
+62% 


114,097 
-102% 


91,329 

+62% 


91.329 

+62% 


91.329 

+62% 


91.329 
-62% 


Young 2nd Growth 
46-115 Years 


82,176 


71.010 
-14% 


71,033 
-14% 


71,048 
-14% 


71,054 
-14% 


89,141 
8% 


71,126 
-13% 


71.120 
-13% 


70.538 

-14% 


71,052 
-14% 


Mature 
116-195 Years 


79,807 


74.503 

-7% 


75,736 
-5% 


76.242 

-4% 


76.614 
-4% 


89,885 

- 1 3% 


79.645 


80.418 
1% 


85.171 

-7% 


76.291 

-4% 


Old Growth 
196+ Years 


1 10,864 


66,527 
-40% 


70,640 
-36% 


72.378 
-35% 


73.604 
-34% 


34.996 

-68% 


85,751 
-23% 


87,623 
-21% 


103,196 

-7% 


74,378 
-33% 



These columns may not have the same total acres due to the differences in the land 
especially true for Alternative 5, which also utilizes the 1972 land base and inventory 



use allocations of each alternative. This is 



Source: BLM allowable cut printout and district inventory. 



67 



impacts ground vegetation to different degrees 
relative to the soil disturbance resulting from the 
harvest system used. 

Broadcast burning is the one method of slash 
disposal proposed under each alternative. The 
short- and long-term effects of burning are relative 
to the severity of the burn. According to research 
in the Coast Range of western Oregon (Morris 
1970), 5.8 percent of the total area burned was 
severely burned. While 16.6 percent of the area 
remained unburned, 22.2 percent and 55.4 percent 
received moderate and light burns, respectively. 
The lighter burn provides a greater percent of 
herbaceous and brush cover within the first 2 
years after burning. Scheduled replanting of 
coniferous seedlings in the area would contribute 
to the alteration as a fire-induced plant community 
became established. The study also showed that 
natural restocking of coniferous species was 
approximately 30 percent greater on burned, as 
compared to unburned, sites in the first 4 years. 

Coniferous seedlings raised in nurseries would be 
planted (Table 1-2). Under the best possible site 
conditions, rapid natural regeneration could occur 
every 3 to 7 years, depending on seed crops. 
Under artificial regeneration, seedlings are 
generally planted the first year following harvest. 
Because the planting stock is already two or more 
years old, it can have a competitive advantage on 
good sites and an even greater advantage on 
poorer sites. Therefore, planting shortens the 
amount of time required for succession to 
progress beyond the grass/forb and 
shrub/seedling stages. The major long-term 
impact associated with planting is that, by 
increasing the competitive advantage of Douglas- 
fir, early successional stages are more quickly 
passed through, and Douglas-fir attains site 
dominance more rapidly. This acceleration not 
only reduces the residence time of early 
successional stages but also precludes the 
development of maximum plant diversity. Planting 
an estimated 15,200 acres with genetically 
improved trees during the 10-year period would 
not have a significant effect on the natural gene 
pool in either the short or long term. No significant 
adverse long-term impacts are anticipated with the 
eventual planting of genetically improved trees on 
90 percent of the intensive timber production base 
for each alternative. Maintaining a broad selection 
of parent trees would ensure variability in genetic 
base populations. The artificial regeneration 
program on BLM-administered lands is not 
expected to significantly affect the stand or 
species composition of the entire Roseburg Area. 
(BLM administers 29 percent of the total forested 
lands. Compare Appendices E and F.) 

Herbicides are used to manipulate the species 
composition, size, density, vigor and presence of 
vegetation. Plant habitat altered by herbicides 
would increase over that in the past decade in all 



alternatives except 7 and 8. Applications are 
targeted to control grass and broadleaf species to 
provide a competitive advantage for conifers. 
Because different herbicides work best for 
selected target species, herbicides are often used 
in combinations. In forestry applications, the 
desired effect is acceleration of plant succession 
from early successional stages to later stages 
dominated by conifers. Gratkowski and 
Lauterback (1974) reported on the height growth 
of young Douglas-fir for a 5-year period after 
release. Percentage increase in height growth over 
non-released trees varied from 130 percent (for 
trees one foot high when spraying occurred) to 
149 percent (for trees six feet high) for basal spray 
plots and from 255 percent (for trees one foot 
high) to 171 percent (for trees six feet high) for 
aerial spray locations. 

Non-target vegetation immediately adjacent to 
spray units may be affected by the movement of 
herbicides through the air. Such impacts are 
limited, but not eliminated entirely, by buffer strips 
and by application techniques (Gratkowski 1974). 
Although the direct vegetational impacts of 
herbicide application are short term, the effects of 
accelerating the establishment of conifer stands 
are long term. Once the coniferous stands become 
dominant they remain until the trees are harvested 
or until natural disasters remove them. For greater 
detail on herbicides and the provisions for 
monitoring of herbicide application, see the FEIS 
Vegetation Management with Herbicides: Western 
Oregon - 1978 through 1987 (USDI, BLM 1978). 

Some timber stands would be fertilized under all 
alternatives except 5, 7 and 8. This practice would 
result in immediate increases of nutrient 
availability for all vegetation on the site. However, 
resultant increased vigor and growth are directed 
at commercial conifer species. These are short- 
term impacts lasting for an average of 7 years, 
depending on site quality. 

Sensitive, Threatened or 
Endangered Plants 

Unidentified populations of sensitive, 
threatened or endangered plant species could be 
susceptible to any impacts described under 
terrestrial vegetation. The direct effects of injury or 
death to the plants could cause the immediate 
elimination of a species in all or a significant 
portion of its range. The more subtle effects of 
vegetative community changes could cause the 
eventual elimination of a species locally through 
loss of competitive ability relative to other 
vegetation on the site. 

If any species of vascular plant is determined by 
the U.S. Fish and Wildlife Service to be threatened 
or endangered, any action that contributes to its 
extinction or to its threatened or endangered 
status would be in violation of the Endangered 



68 



Species Act of 1973 as amended. Therefore, 
environmental analysis accomplished prior to any 
site specific action would include any threatened 
or endangered plant species known to be present 
on the site and appropriate measures to be taken. 

Conclusions 

Alterations to plant community structure and 
longevity would be the most significant impacts to 
terrestrial vegetation on those lands included in 
the timber production base. Continued timber 
management would not allow natural succession 
to replace these communities because future 
forests would be harvested before they reached 
the 90-year age class. 

Ecosystem management assumes that every 
component of a naturally functioning system 
serves a purpose and that each component 
benefits the system. At the present time, there is 
no definitive description of the functioning of the 
old growth system and its importance to long- 
range timber production. 

The symbiotic relationships between plants and 
animals that function in old growth stands are not 
fully understood and may prove to be important to 
long-term timber production. Until this is 
understood, maintaining a representative range of 
the old growth forest and associated floral and 
faunal genotypes is important. All alternatives 
would to provide an adequate representation of 
the original old growth systems over the short 
term. 

The short-term use of the commercial forest lands 
for timber harvest would increase the long-term 
production of wood fiber as old, slow-growing 
stands are replaced by young, fast-growing stands 
managed for optimum wood production. In the 
long term, as the area approaches a balance of age 
classes, maximum growth of commercial 
coniferous species is achieved. 

Changes in plant communities and habitat could 
eliminate some plant species over the long term. 
Intensive timber management practices such as 
planting and herbicide application would favor 
survival of coniferous trees. However, elimination 
of hardwood trees, shrubs and herbaceous 
vegetation would not occur. 

An additional type of impact involves the 
management option of using a lower minimum 
harvest size (MHS). A significant trade off between 
short-term use and long-term productivity exists. 
Alternative 3 differs from 4 in that it utilizes a lower 
MHS (see Chapter 1). Over the short term (the first 
10 years), Alternative 3 would allow harvest of 70 
MM bd. ft. (7 MM bd. ft./year) above that of 
Alternative 4. However, over the long term, total 
productivity would be less. Maximum growth and 
yield are attained when a regulated forest is 
achieved, producing an estimated annual harvest 



of 303 MM bd. ft. on the timber production base of 
Alternative 4. Alternative 3 would have an annual 
harvest higher than Alternative 4 until 
approximately the 13th decade, when Alternative 4 
achieves regulation. During this time, a total 
harvest of 910 MM bd. ft. above the Alternative 4 
level would be realized. Beginning in the 13th 
decade, Alternative 4 would produce the higher 
annual harvest (303 MM bd. ft. at the regulation 
level) until Alternative 3 achieves regulation in 
approximately the 30th decade. During those 17 
decades, Alternative 4 would produce an 
additional 7,990 MM bd. ft. for harvest. Therefore, 
over the long term (at least 30 decades into the 
future), Alternative 4 would produce 7,080 MM bd. 
ft. more than Alternative 3. A similar relationship 
would exist for all alternatives which utilize a 50 
year minimum harvest age. 

Existing older forest communities scheduled for 
final harvest would be converted to early 
successional stage communities. This impact is 
unavoidable. Table 3-9 indicates the amount of old 
growth habitat that would be irretrievably lost as 
long as those acres are managed intensively for 
timber production under all Alternatives except 8. 
Permanent new road construction ranging from 
1 ,662 acres in Alternative 8 to 5,568 acres under 
Alternative 1 would result in the unavoidable 
elimination of vegetation on these acres. 

Impacts on Animals 

Timber operations impact both animals and 
their habitats. In most cases, the greatest and 
longest-term impacts occur on animal habitats, 
rather than on individual animals. Thomas (1979), 
Meslow (1977) and Wight (1974) have shown that 
certain species of vertebrates are associated with 
forests that are of a particular age class and 
resulting structure. Some species habitat 
requirements are rigid, others are more flexible. 
Appendix D lists species occurring in the SYUs 
and their association with various habitats. 

The predicted structure of habitat on BLM- 
administered forest lands (Appendix E) was 
calculated using the allowable cut runs and district 
inventory data. In an attempt to place BLM plans in 
perspective, the predicted structure of habitat in 
the entire EIS area (as defined in Chapter 2, 
Animals) was also estimated by applying 
extremely rough projections of harvest levels (by 
ownership) on all these lands over the first 10 
decades (see Appendix F). 

Terrestrial Vertebrates 
Transportation System 

Road construction would eliminate vegetation 
from the roadbed. The acreage would vary (see 
Table 1-2) depending on the alternative selected. 
Currently about 12,000 acres have been cleared for 
roads. The added impacts of habitat elimination 
would be adverse and perpetual since most road 



69 



Table 3-9 Acres of Old Growth* (196+ 


) and Percent Change from Existing 


on BLM-Administered Lands Remain 


ing at the End of Each Decade 


(Current: 110,900 


acres) 






Alt. 1 


Alt. 2 Alt. 3 


Decade 


Max. Tbr. 


Emp. Tbr. Lo MHS 


1 


66,500 (-40%) 


70,600 (-36%) 72,400 (-35%) 


2 


28,700 (-74%) 


36,300 (-67%) 40,900 (-43%) 


3 


8,600 (-92%) 


16,600 (-85%) 28,400 (-74%) 


4 


8,700 (-92%) 


16,400 (-85%) 27,800 (-75%) 


5 


8,900 (-92%) 


16,600 (-85%) 27,900 (-75%) 


6 


9,000 (-92%) 


16,100 (-85%) 26,800 (-76%) 


7 


9,000 (-92%) 


15,700 (-86%) 25,800 (-77%) 


8 


13,500 (-88%) 


20,500 (-82%) 31 ,300 (-72%) 


9 


13,600 (-88%) 


21,000 (-81%) 31,800 (-71%) 


10 


13,700 (-88%) 


21,100 (-81%) 31,800 (-71%) 




Alt. 4 


Alt. 5 Alt. 6 


Decade 


OPA 


No Action HD 


1 


73,600 (-34%) 


35,000 (-68%) 85,800 (-23%) 


2 


42,400 (-62%) 


13,000 (-88%) 66,500 (-40%) 


3 


28,400 (-74%) 


4,800 (-96%) 59,300 (-47%) 


4 


27,800 (-75%) 


5,000 (-95%) 57,800 (-48%) 


5 


27,900 (-75%) 


5,400 (-95%) 58,200 (-48%) 


6 


26,800 (-76%) 


5,500 (-95%) 55,800 (-50%) 


7 


25,800 (-77%) 


5,600 (-95%) . 54,600 (-51%) 


8 


31,300 (-72%) 


6,300 (-94%) 62,700 (-43%) 


9 


31,800 (-71%) 


6,800 (-94%) 66,100 (-40%) 


10 


31,800 (-71%) 


7,300 (-93%) 68,100 (-39%) 




Alt. 7 


Alt. 8 Alt. 9 


Decade 


No Herb. 


Full Eco. NPA 


1 


87,600 (-21%) 


103,200 (-7%) 74,400 (-33%) 


2 


71,400 (-36%) 


106,100 (-4%) 42,800 (-61%) 


3 


53,600 (-52%) 


105,000 (-5%) 31,000 (-72%) 


4 


53,900 (-51%) 


103,600 (-7%) 31,000 (-72%) 


5 


56,200 (-49%) 


106,000 (-4%) 31,800 (-71%) 


6 


55,800 (-50%) 


1 02,400 (-8%) 31 ,300 (-72%) 


7 


55,400 (-50%) 


101,100 (-9%) 30,800 (-72%) 


8 


63,700 (-43%) 


1 13,500 (+2%) 37,000 (-67%) 


9 


67,500 (-39%) 


119,500 (+8%) 38,200 (-66%) 


10 


70,000 (-37%) 


123,500 (+11%) 38,900 (-65%) 


* Rounded to nearest 100 acres 






Source: BLM allowable cut printout and district inventory. 





systems would be maintained indefinitely. 
Increased mortality due to collisions with vehicles 
is unpredictable but probably insignificant. 

Harassment of wildlife by vehicles undoubtedly 
would occur and during stress situations, such as 
times of temperature extremes, would adversely 
affect the animal's physiological mechanisms and 
mortality could occur. Losses to this cause would 
not be expected to be large or significant to the 
population as a whole. New miles of roads mean 
more access by hunters and increased harvest and 



harassment is probable. Legal harvest can be 
limited by regulations adopted by the Oregon Fish 
and Wildlife Commission but an increase in 
poaching is probable. This could lead to 
depressed deer and elk populations in local areas. 

Lyon (1979) and Perry and Overly (1977) have 
shown that elk use is reduced within one-half mile 
of roads traversing elk habitat. This reduced use 
varies with terrain, cover, distance and other 
factors, so an accurate quantification is possible 
only on a site specific basis. However, the 



70 



probable effects of a mile of road through elk 
habitat can be described in general terms. 
Vehicular use of a road will affect elk use of the 
adjacent habitat. This influence on use may extend 
for at least 660 feet on either side of the road, thus 
affecting an area of 160 acres per mile of road. It is 
estimated that elk use of this 160 acres may be as 
much as 75 percent less than that of similar habitat 
not influenced by road use. Such a reduction in 
habitat use must be considered adverse. Effects of 
roads on deer are "variable and relatively 
insignificant" (Perry and Overly 1977, page 34). 

All alternatives contain provisions to close some 
roads in order to reduce harassment and 
poaching. Past experience has shown these 
closures difficult to enforce. Once roads are 
effectively closed, elk use increases to near normal 
levels. In the Tyee area planned road closures 
should improve elk use of habitat adjacent to 
roads. 

Timber Harvest 

The greatest effect timber harvest would 
have on terrestrial vertebrates during the first 
decade would be the modification of habitat by 
clearcutting. The amounts range from 66,780 acres 
in Alternative 1 to 19,915 acres in Alternative 8 (see 
Table 1-2). The removal of mature and old growth 
stands eliminates the habitat of those species of 
animals adapted to exist there. If similar 
unoccupied habitat exists nearby, then those 
displaced individuals could occupy them. It is 
unlikely that such a situation exists as it is 
assumed that habitats are currently at carrying 
capacity. 

For certain species (e.g. elk, deer, spotted owls 
and other cavity dwellers) which are influenced by 
habitat availability and arrangement, efforts will be 
made during the first decade to schedule the 
harvest of mature and old-growth forest to benefit 
these species or to minimize adverse impacts. 

In the short term, all alternatives except 5 would 
have at least 65,000 acres of old growth forest 
remaining. Although the arrangement of this 
acreage may not be optimum for all species, there 
would likely be sufficient habitat after one decade 
of management to retain a representative 
ecosystem. 

In Alternatives 3, 4 and 7, approximately 52,000 
acres (Table 1-3) are proposed for modified area 
control management, and with the exception of 
riparian zone habitat on third order and larger 
streams, the lands are confined to corridors. (The 
riparian zones are scattered across the district.) 
Mature and old growth forests, a necessary 
element of habitat diversity, would be located in 
these corridors. These also are the lands that 
would provide the major portion of the snags for 
cavity dwellers, northern spotted owl habitat, 
survival cover for elk and ties to other corridors. 



For Alternatives 2 and 9 the same issues are 
applicable, but the land area proposed for 
management is 24,800 and 35,900 acres, 
respectively. In Alternative 9 no harvest is planned 
from riparian zones on third order and larger 
streams. 

Currently there are about 110,900 acres of old 
growth (196+ years) on BLM-administered timber 
lands in the SYUs (Table 3-8). If Alternative 8 were 
selected, old growth would increase over time and 
have a beneficial impact on species using this 
habitat (Table 3-8 and Appendix E). However, if 
any other alternative were chosen, old growth on 
BLM-administered land would decrease over time. 
The decreases range from 37 percent in 
Alternative 7 to 93 percent in Alternative 5 (see 
Table 3-9 and Appendix E). Related decreases in 
animals (see Appendix D) that find their optimum 
habitats in these stages would be probable. 
Examples are the big brown bat, northern flying 
squirrel and pileated woodpecker. The actual 
viable old growth habitat is less than appears in 
Appendix E because a portion of the remaining old 
growth would be in riparian zones that, because of 
their long, narrow configuration, would not have 
true old growth habitat characteristics. In the long 
term, enough mature and old growth habitat would 
be provided by Alternatives 6 through 8 to assure 
maintenance of viable populations of animals 
dependent on these habitats. Alternatives 1 
through 5 and 9 would not do this. 

When habitat structure on all lands in the EIS area 
(see Chapter 2, Animals) is examined (Appendix 
F), old growth would decline in all alternatives. In 
the long term, all old growth timber remaining in 
the EIS area would be on Federal lands 
administered by BLM and U.S. Forest Service. 
With this reduction of old growth habitat, a related 
reduction of old growth dwelling populations 
would be probable (see Appendix D). 

The Tyee area is the most important elk area in the 
Roseburg SYUs. In total it comprises about 5 
percent of the State's Tioga Wildlife Management 
Unit, which has historically produced the majority 
of the elk harvested in southwest Oregon. 

Planned timber management activities in the Tyee 
area would change existing habitat conditions and 
influence elk populations as shown in Table 3-10. 
In the short term elk populations would increase in 
the Tyee area under all alternatives as a result of 
increased forage produced by clearcut harvest, 
provided that vehicle access does not lead to 
increases in harassment and poaching. Planned 
road closures should help reduce such problems. 
For all alternatives the population would peak in 
the second decade, then decline to a level similar 
to that which presently exists by the end of the 
second decade. In the long term, 30 to 50 years 
hence, a gradual decline from second decade 
levels is expected for all alternatives except 8. The 



71 



Table 3-10 Estimated Elk Population 
Changes on BLM-Administered 
Lands in the Tyee Area 1 


Alternative 


2nd Decade 


5th Decade 


10th Decade 


1 
2 
3 
4 
5 
6 
7 
8 
9 


No change 
No change 
No change 
No change 
No change 
No change 
No change 
No change 
No change 


-25% 
-25% 
-25% 
-25% 
-10% 
-5% 
-20% 
No change 
-25% 


-25% 
-20% 
-30% 
-20% 
-20% 
-5% 
-20% 
No change 
-20% 


1 All values ±5 percent 






Source: BLM District and State Office personnel 





estimated elk population 50 to 100 years in the 
future is expected to be 20 to 30 percent less than 
present levels for Alternatives 1 through 5, 7 and 9. 
Alternative 6 is expected to show a 5 percent 
decline, while Alternative 8 no change. 

Because of its importance to elk, the Tyee area has 
certain management prescription designs to 
benefit elk in Alternatives 3, 4, 7 and 9. They 
include: 30 to 40 percent of clearcut area 
consisting of smaller (15-20 acre) clearcuts and of 
a shape which maximizes edge habitat; a distance 
to cover not to exceed 500 feet within those 
clearcut units; and a minimum cover width 
adjacent to units of 200 feet. These design features 
along with planned road closures would benefit 
deer and elk and help reduce long-term adverse 
impacts in this area. 

Decreases in mature habitat (116-195 years old) 
would occur in all alternatives. The decreases 
would have an adverse impact upon the animal 
populations occurring there. 

In Alternatives 1 through 7 and 9, increases occur 
in pole/sapling and young second growth and 
associated animal populations would have 
corresponding changes (see Appendices E and F). 

Early successional stages (1-15 years) following 
harvest would benefit some species. The savannah 
sparrow, brush rabbit, mountain beaver, deer, elk 
and mountain quail are examples of species that 
use early successional stages. There are currently 
some 75,000 acres of early serai stage (less than 
15 years old) vegetation on BLM-administered 
timber land and an additional 370,000 acres of like 
habitat on other ownerships within the SYUs. 
Since this stage presently comprises about 30 
percent of the total land base and will continue as 
such in the future, there would be adequate levels 
in both the short and long term to meet the habitat 
needs of species associated with these 



successional stages. 

In future decades, except for Alternative 8, 
clearcutting acreage would decrease while 
commercial thinning dramatically increases. 
Commercial thinning would occur in the 
pole/sapling and young second growth that 
account for the majority of habitat remaining at the 
end of 10 decades (see Table 1-2 for acreage to be 
thinned during the first decade). 

Commercial thinning removes up to 40 percent of 
the basal area of the forest and has several effects 
on wildlife habitat. The structure of the forest 
becomes more simplified and animal species 
diversity decreases. The stand is opened up and its 
value as thermal cover is reduced (Edgerton and 
McConnell 1976). Hiding cover is also reduced and 
forage may not increase, for as Edgerton (1972) 
pointed out, deer and elk use is less in partial cut 
areas (30 percent basal area removed) than in 
either clearcuts or unlogged stands. These 
alterations resulting from commercial thinning 
would result in lowered deer and elk populations 
in comparison to present day clearcut 
prescriptions. 

Forest birds would be affected. As Franzreb and 
Ohmart (1978) show, thinning decreases habitat 
value for birds that forage by searching in the tree 
foliage or gleaning in timber. Species such as red- 
breasted nuthatch and golden-crowned kinglets 
would be reduced, while ground feeders such as 
the robin and house wren would increase. 

Cooper's and sharp-shinned hawks use dense 
second-growth Douglas-fir as their primary 
nesting habitat (Reynolds 1971). The quality and 
quantity of this habitat would be reduced by 
commercial thinning. 

Commercial thinning is not expected to result in 
any significant adverse effects on wildlife in the 
short term because of the small proportion of the 
land base scheduled for treatment. 

The skidding of logs during yarding destroys low 
vegetation and compacts the soil. The complete 
but temporary destruction of surface vegetation 
due to yarding (see Table 3-2) would reduce the 
amount of habitat for small rodents and 
insectivores. Ground disturbances that do not 
remove excessive topsoil may benefit local wildlife 
populations such as elk and deer, seed-eating 
birds and certain rodents that depend on early 
sucessional communities. Swanson (1970, cited in 
Bunnell and Eastman 1976) reported significantly 
higher elk use on moderately or heavily disturbed 
sites than on lightly disturbed sites. 

Snag-dependent wildlife such as woodpeckers and 
other cavity dwellers would be adversely affected 
due to snag removal during harvest operations. 
Based on the work of Thomas (1979), three snags 
of prescribed sizes per acre would provide for 



72 



maximum populations of primary excavators. To 
manage primary excavators at the 60 percent level 
(considered a safe level) requires about two snags 
(of prescribed sizes) per acre. Most private lands 
are not routinely managed for cavity users; 
therefore, the habitat component maintained on 
BLM-managed lands is crucial to the survival of 
snag-dependent species. District surveys revealed 
that snags and/or wildlife trees are being provided 
at the rate of 0.1 per acre on recent harvest units. 

Using the snag management components 
displayed in Table C-4, Table 3-11 was developed 
to describe expected long-term snag densities on 
the BLM-administered land base. 

As can be seen from the table, only Alternative 8 
reaches the 60 percent management level, 
although Alternatives 6 and 7 are close. To provide 
maximum wildlife benefits, snags should approach 
an even distribution throughout the land base. 
Alternative 8 is the only one that approaches even 
distribution. 

During the first decade, impacts would be minimal 
because of the large amount of unharvested land 
in the SYUs. However, for all alternatives except 6, 
7 and 8, snag dwelling species would decline to 
below BLM target levels in the long term (see 
Table 3-11). This would be a significant adverse 
impact as populations would fall below self- 
sustaining levels. 

New snags are created by natural mortality in the 
forest. All alternatives except Alternative 8 would 
employ some amount of mortality salvage during 
the decade (see Table 1-2). The number of trees 
per acre, their age and size are variable and not 
predictable. While in general the impacts would 



not be immediately significant, these trees are the 
snags and down forage logs of the near future and 
removing them eliminates potential and needed 
habitats. 

Riparian habitat is important as 88 percent of the 
terrestrial wildlife species in the area use it to 
some degree. The importance of this habitat is the 
result of many factors, including cover, food, 
water, edge and microclimate. The maintenance of 
its values depends on sustaining the structural 
integrity of the vegetation. Any alteration of its 
structure decreases its value to terrestrial wildlife. 
For most riparian areas, best management for 
wildlife means no entry. 

Table C-4 shows how each alternative treats 
riparian zones. Alternative 8 is the only alternative 
which provides any protection to small first and 
second order streams unless they occur in an area 
under other forms of management in the 
constrained timber base. Approximately 12,150 
acres of this habitat (first and second order 
streams) would be modified and replaced by 
younger vegetation if any alternative except 
Alternative 8 were selected. Riparian habitat next 
to first and second order streams is more like 
adjacent upland habitat and its loss is not as 
important as the loss of riparian habitat on higher 
order streams. 

Riparian vegetation on third order and larger 
streams would undergo some planned harvest in 
all alternatives except Alternatives 6, 8 and 9. 

Alternative 1 would substantially alter riparian 
habitat and the impacts would be significantly 
adverse. Management by modified area control as 
proposed in Alternatives 2, 3, 4 and 7 would also 



Table 3-11 Long-Term Snag Density 



Alt. 


Snag/ac 


Percent 

Management 

Level 


1 


0.13 


<10 


2 


0.32 


10 


3 


0.77 


20-30 


4 


0.77 


20-30 


5 


0.21 


<10 


6 


1.43 


40-50 


7 


1.25 


40-50 


8 


2.24 


70-80 


9 


0.77 


20-30 



Snag Distribution 

Would not occur on 96% of land base; 

adequate on 4% of land base 
Would not occur on 89% of land base; 

adequate on 11% of land base 
Inadequate occurrence on 82% of land base; 

adequate on 18% of land base 
Inadequate occurrence on 82% of land base; 

adequate on 18% of land base 
Would not occur on 93% of land base; 

adequate on 7% of land base 
Would not occur on 47% of land base; 

adequate on 53% of land base 
Inadequate occurrence on 65% of land base; 

adequate on 35% of land base 
Would not occur on 25% of land base; 

adequate on 75% of land base 
Inadequate occurrence on 82% of land base; 

adequate on 18% of land base 



73 



alter riparian habitats on those acres entered. A 
yearly average of 12 acres clearcut and 96 acres 
partial cut of third order and larger riparian zones 
would be expected. The significance of this 
disturbance is amplified as "Habitat alteration [in 
riparian habitats] will affect wildlife far more than 
indicated by the proportion of the total area 
disturbed" (Thomas 1979). 

Food supplies for grazers and browsers are more 
readily available in the early successional stages 
as compared with other successional stages. Deer 
and elk use would increase and peak six to eight 
years following clearcutting (Harper 1969; Crouch 
1974). However, the food supply may not be 
utilized if sufficient hiding or escape cover is not 
nearby. To.assure sufficient wildlife cover, 
clearcuts should not exceed 40 acres. In the 
sample five-year timber sale plan, 59 of the 953 
sale units would exceed 40 acres in size. The size 
ranges from 2 to 51 acres, but averages 27 acres. 
Clearcut size is only part of the mechanism 
necessary to provide cover near feeding areas. The 
other is to allow regrowth to provide cover (about 
10 years) prior to clearcutting on adjacent lands. 
Without this timing, the forage created may not be 
utilized as no cover is available. Alternatives 6 and 
8 provide for 10- and 15-year intervals respectively, 
between adjacent clearcut units, and all other 
alternatives provide for at least 3- to 5-year 
intervals. As part of harvest scheduling design 
features, a 10-year interval would be applied to all 
lands under Alternative 9, where possible during 
the first decade, so long as it did not limit the 
ability to meet the prescribed allowable cut. 
Should conflicts arise between the 10-year spacing 
standard and meeting the allowable cut level, the 
interval would be lowered. Such design features 
serve to distribute harvest units, mitigating adverse 
impacts to species which utilize mature and old- 
growth forest habitat. 

Other Timber Management 
Treatments 

Other treatments (Table 1-2) alter animal 
habitat through vegetative manipulation. 

Slash burning would eliminate most live vegetation 
from the site and 80 to 90 percent of the 
combustible material less than three inches in 
diameter would be consumed. Larger material is 
generally charred in place. Table 1-2 lists acres to 
be burned for all alternatives. These effects vary 
with the intensity of the burn, but immediate 
impacts would be removal of vegetation and on 
site reduction of associated animal populations. 
This would last less than one growing season, 
after which a vigorous growth of grasses and forbs 
would appear and animal populations adapted to 
early successional stage vegetation would 
increase. 



The removal of woody material reduces 
obstructions to deer (Crouch 1974). Other species 
such as juncos and wrens use logging slash as 
activity centers. Juncos declined when slash was 
burned (Franzeb and Omart 1978). Charring of the 
larger material removes bark and eliminates micro- 
habitats for invertebrates that are an important 
item in the food chain. In addition, the resulting 
habitats lack structure that slash provided and are 
more simplified. 

Harper (1969) reported higher Roosevelt elk use 
on logging sites that had been burned than on 
those that had not been burned, and explains that 
on burned sites grasses were more than three 
times as abundant. Grasses are a preferred food 
item of elk. He warned, however, that slash 
burning would not necessarily increase forage and 
subsequent elk use on all sites as physical 
characteristics make each site different in its 
response to burning. Also, Crouch (1974) 
indicated that slash burning increased the food 
supply for black-tailed deer. In the Roseburg SYUs 
grasses are commonly found in the early serai 
stage plant communities. Some clearcut units 
throughout the district are dominated by grasses. 
This includes clearcuts in the Tyee area, the 
primary elk use area. 

Mechanical piling of slash would cause soil 
disturbance and have impacts similar to those 
caused by yarding. Piling removes downed slash 
that may cause barriers to large ungulates. 
Subsequent burning removes these barriers and 
enough debris may be left to provide habitat for 
some birds and small mammals. 

All alternatives except Alternative 7 call for 
herbicide use in site preparation and conifer 
release during the decade. The impacts from all 
alternatives except Alternative 7 are the same, only 
the magnitude changes. (See Table 1-2 for acres 
treated.) 

There are four major types of impacts to animals 
that could be associated with silvicultural 
herbicide application: exposure to acute toxic 
levels, exposure to chronic toxic levels, habitat 
modification and carrier impacts. The following is 
a brief discussion of these four impacts. Additional 
information may be obtained from the final EIS on 
herbicides (USDI, BLM 1978). 

Newton and Norris (1968) sampled blacktail deer 
taken from treated sites (2,4,5-T & Atrazine), and 
were unable to detect residues in most tissues. 
One animal was found to have a trace in the liver. 
In a study by the manufacturer, goats given 0.2 mg 
triclopyr/kg daily for 10 days were found to have 
tissue residues above the detection limit of 0.003 
ppm in only the liver (0.004 ppm) and kidney 
(0.013 ppm). 



74 



According to Dost (1983), if an assumption of feed 
intake by deer at 3 percent of body weight per day 
is taken, at the hypothetical maximum of 400 ppm 
of herbicide in browse, intake will be 30 grams 
feed/kg or 12 mg herbicide/kg. In the goat study 
the maximum concentration in muscle was 
between zero and 0.003 ppm, and will be taken as 
0.003 ppm. Studies in other species show that 
tissue concentration is proportional to dose rate. 
The proportional concentration in the animal's 
muscle would be 0.18 ppm (0.18 mg/kg) and/0.24 
ppm (0.24 mg/kg) and 0.78 ppm (0.78 mg/kg) in 
the liver and kidney respectively. To acquire these 
dosage levels, an animal would have to forage in 
freshly treated areas for 10 consecutive days 
providing there would be no chemical breakdown 
or deterioration. Therefore, the potential for 
wildlife to suffer acute or chronic toxic effects is 
unlikely at proposed herbicide use rates (see 
Tables 1-4 and 3-17). 

Herbicides have pronounced impacts on wildlife 
habitat. These impacts are brought about by 
losses of habitat diversity and stratification 
resulting from the temporary setback of certain 
plants that are in competition with the desired 
coniferous species. This would adversely impact 
those animals that utilize the grass/forb and 
shrub/seedling successional stages. 

Diesel oil is sometimes used as a carrier for forest 
herbicides. Data on the toxicity of diesel oil on 
wildlife are limited; however, some work has been 
done on the adverse effects on adult ducks 
(Tucker and Crabtree 1970; Hartung 1966; Hartung 
1965). It is unlikely that wild animals would 
consume lethal amounts of the carrier because of 
the dilution factors involved. It may, however, 
adversely affect the palatability of the forage. 
Other potential impacts include the coating of 
eggs, thereby affecting their hatchability, and the 
wetting of individuals, making them more 
susceptible to other environmental stresses. 
However, data are insufficient to predict the 
impacts of diesel oil carrier on animals in the EIS 
area. 

Precommercial thinning, although it may open a 
young forest canopy, generally does not benefit 
deer and elk because the unremoved slash 
impedes movements. The obstacle presented by 
slash accumulations restricts deer and elk from 
utilizing any forage increases which result from 
the thinnings. Cover use is also restricted by slash 
accumulations. Therefore, reduced deer and elk 
use would occur on those acres precommercially 
thinned (see Table 1-2). This condition could last 
as long as two decades before decomposition 
removed the obstacles. 

Conversely, birds and small mammals may 
increase their use of an area following 
precommercial thinning. Slash accumulations 
provide cover for them and any increases in forage 
production can be utilized. 



Fertilization increases the growth and palatability 
of many plant species. These increases may be 
utilized by wildlife which would be a short-term 
positive impact. 

Fish 

Impacts of timber management on fish and 
aquatic habitat fall into the broad categories of 
increased accumulation of bottom sediments, 
increased amounts of suspended sediments, 
altered amounts of stream flow, introduction of 
logging debris, change of water temperature, 
destabilization of banks and channels and 
reduction of instream structure. 

The impacts from the nine alternatives differ 
primarily in magnitude. These differences reflect 
the acres of land treated and miles of road built. 
For instance, Alternative 8 has the fewest miles 
constructed, while Alternative 1 has the most miles 
of road constructed. (See Table 1-2 for all 
treatments.) 

On lands administered by BLM in the SYUs, there 
are approximately 270 miles of streams that 
support cold water fish (see Table 2-11). Analysis 
of the sample 5-year timber sale plan shows that 
approximately 17 miles of stream that support cold 
water fish pass through or are adjacent to 77 
harvest units. 

Aquatic invertebrates, which are important both as 
food for fish and as indicators of stream quality, 
can also be modified or destroyed by the same 
factors that affect fish habitat. It is assumed that 
impacts to most invertebrates would be similar to 
those experienced by fish in localized areas. 
Research by Erman et al. (1977) revealed that 
when buffer strips of at least 30 meters (about 98 
feet) width on each side were maintained, the 
macro-invertebrate populations were 
indistinguishable from those of unlogged stream. 

Maintenance of buffers helps minimize stream 
degradation. Since Alternative 1 has no provisions 
for buffer strips except as provided by the Oregon 
Forest Practices Act, stream productivity might be 
adversely affected. 

Chapter 3, Impacts on Water Resources, provides 
data on expected amounts of sediments and water 
that would reach the streams of the SYUs and 
compares them to existing amounts. Many of the 
analyses and conclusions appearing in this section 
are based on those data. 

Transportation System 

The construction of roads can add greatly to 
the sediment load of a river. In Alternatives 1, 2, 3, 
4 and 9, road building during the decade would be 
more than in the past decade; however, 
sedimentation from road building would be 
increased only in Alternatives 1 and 2 (see Table 3- 
6). Analysis of the sample five-year timber sale 



75 



plan shows about three miles of road would be 
built on fragile or unstable soils that are adjacent 
to streams with fishery values. If sedimentation 
increased, the impacts would be adversely 
significant to localized areas. Downstream 
sedimentation could occur and could have 
significant effects. 

In discussing impacts to the aquatic invertebrates, 
Erman et al. (1977) suggest that repeated failure of 
road crossings was the cause of disruption of the 
stream biota, not the construction of road 
crossings. Investigations in the vicinity of newly 
installed culverts showed only a slight impact. 

Three new roads identified in the sample five-year 
timber sale plan would cross streams with fishery 
values. All are on stable soils so only short-term 
localized impacts are expected. 

Timber Harvest 

Timber harvest can have an adverse impact on 
fish habitat by removing the riparian zone, 
changing water yield and increasing 
sedimentation. 

Removing the riparian zone, including old growth 
conifers, would increase the amount of fine 
organic material, reduce the number and quality of 
pools, reduce useable spawning gravels, reduce 
macro-invertebrate production areas, destabilize 
banks and channels, and increase water velocities. 
Logging riparian zones would also increase 
sedimentation of stream bottoms and change 
temperature regimes by decreasing shade. 
However, where some streamside vegetation is 
retained, no change in temperature was observed 
(Brown and Krygier 1970). Water temperatures 
would not increase if Alternatives 2 through 9 were 
selected. Alternative 1 makes no provision for 
riparian buffers and water temperatures would be 
expected to increase. These increases are not 
quantifiable but impacts are expected to be 
adverse. 

Clearcutting increases water yield (see Impacts on 
Water Resources), which could have a scouring 
effect on stream bottoms, thereby removing gravel 
and aquatic vegetation. Based on the analysis 
described in Chapter 3, it is estimated that water 
yield changes would have a negligible impact to 
the SYUs as a whole. 

Harvest and yarding could contribute considerable 
sediment to local streams. Increases in bottom 
sediments, according to Gibbons and Salo (1973), 
cause the most damage of all factors affecting 
aquatic life. The amount of sedimentation would 
depend on the alternative selected. Alternatives 4, 
6, 7, 8 and 9 would reduce sedimentation 
compared to past activities, while Alternatives 1, 2 
and 3 would result in an increase (see Table 3-6). 

While changes in fish production cannot be 
quantified, any increase in sediment would have 



an adverse impact while decreases would be 
beneficial. 

Other Timber Management 
Treatments 

Burning, animal damage control, precommercial 
thinning and fertilization are not expected to have 
a significant impact on fish. 

The chemicals proposed for use for vegetation 
control and the levels of their application are not 
expected to measurably affect aquatic vegetation. 
Streamside vegetation that provides shade could 
be altered in a worst case circumstance. Buffer 
strips along streams should prevent this from 
occurring. However, due to pilot error, some parts 
of these buffer strips could receive applications, 
and some detectable amounts could reach the 
stream. 

Toxic effects of herbicides on fish have been 
documented in the laboratory (U.S. EPA 1977). 
However, proposed field application rates would 
be considerably less than the minimum lethal dose 
for those species tested and toxic effects are not 
expected. (See BLM's FEIS Vegetation 
Management with Herbicides, Western Oregon 
1978 through 1987, for more detailed information.) 
It should be noted that long-term effects, 
particularly under field conditions, are more 
difficult to determine than are effects in short-term 
laboratory tests. Also, Cameron and Anderson 
(1977) felt that more study use was needed in 
order to evaluate the impacts to aquatic plants and 
animals under field conditions. However, Cameron 
and Anderson's monitoring program in 1977 and 
Anderson's monitoring in 1979 showed that 
amounts of herbicides in streams did not exceed 
EPA's "safe" level standards. 

Threatened and Endangered 
Animals 

Threatened and endangered species receive 
special attention under the terms of the 
Endangered Species Act of 1973, as amended, and 
BLM policies and guidelines. Known locations of 
these species are managed and special 
precautions taken to ensure their well-being. (See 
Chapter 1, Forest Management Treatments and 
Design Elements.) Because of their habitat 
requirements and locations, no impacts are 
expected to occur to the Columbian white-tailed 
deer and the bald eagle. 

Transportation System 

Threatened or endangered species would 
probably be affected only to the extent that road 
construction could open previously inaccessible 
areas. This impact cannot be quantified or 
qualified. Where road construction may affect a 
given species, special measures are taken to 
prevent significant adverse impacts. 



76 



Timber Harvest 

Habitat modifications caused by clearcutting 
would have long-term adverse impacts on old 
growth-dwelling species. The northern spotted 
owl, a State-listed species, is dependent on old 
growth closed-canopy forests and would be 
greatly affected. 

The original Oregon Endangered Species Task 
Force management recommendations for each 
pair of owls (in effect during the preparation of the 
proposed MFP) called for total protection of a 300- 
acre old growth core area (if available) and an 
additional 900 acres to be managed such that at 
least 50 percent of this acreage would occur as 
stands of 30+ year-old forests. Based on these 
recommendations, Alternatives 3, 4 and 7 would 
protect habitat for 18 pairs in the long term. 
Alternative 9 would provide habitat for 18 pairs 
under the recommendations, plus an additional 
pair by other allocation for a total of 19 pairs in the 
long term. It is highly probable that at least 25 
viable pairs would remain at the end of the first 
decade as a result of land use allocations and 
harvest scheduling. Alternative 6 would protect 
habitat for 25 pairs, and Alternative 8, habitat for 
55 pairs in the long term. Alternatives 1, 2 and 5 
have no provisions to protect owls in either the 
short or long term. 

Examination of the sample five-year sale plan 
reveals planned harvest units would involve the 
habitat of 23 of the 55 known pairs. Consideration 
will be given to scheduling harvest units to 
eliminate or reduce adverse impacts. 

A revision of Task Force recommendations has 
resulted from recent data. The revision 
recommends that forests be managed to provide 
1,000 acres of old growth per pair of owls within a 
1.5 mile radius of nest sites. Currently, 42 pairs 
occupy habitat that meets this criterion. The 
following analysis of the relationship of the 
alternatives to spotted owl habitat is based on the 
assumption that the revised recommendations 
identify minimum essential habitat. Land use 
allocations in Alternatives 6 and 8 would provide 
enough habitat for 24 and 42 pairs respectively in 
both the short and long term. None of the other 
alternatives would provide habitat for any owls in 
the long term. Because timber sale locations 
beyond the five-year plan are not known, it is not 
possible to predict when various pairs would have 
their habitat removed. 

Conclusions 

With the exception of Alternative 8, both 
short- and long-term reductions of old growth 
would have an adverse impact on old growth 
species. In the short term adequate habitat would 
exist for viable population levels of old-growth 
related species in all alternatives except 5. Short- 
term habitat diversity will improve under all 



alternatives as the serai stage mix is enhanced by 
harvest and succession. Alternatives 1, 2 and 5 
significantly reduce mature and old growth habitat 
in the long term, and selection of one of these 
alternatives would have significant adverse 
impacts on old growth species and habitat 
diversity. In the long term, intensive forest 
practices in Alternatives 1, 2, 3, 4, 5 and 9 would 
lead to even-aged stands that would significantly 
reduce habitat diversity and adversely impact 
wildlife. 

Simplification of forest habitats would also have a 
significant effect on wildlife. Pole, sapling and 
young second growth (which would account for 
most of the forests, except in Alternative 8) have 
low environmental variables (simple structure) 
even under natural conditions. Further loss of 
structure from thinning would make these age 
classes of very low value for most wildlife. Further 
simplification resulting from broadcast burning 
and herbicides would add to the loss of diversity. 
This long-term simplification and loss of diversity 
would be significant and adverse. 

During the short term, snag-dependent wildlife 
would decline but remain at viable levels. 
Continued decline in the long term would reduce 
populations below viable levels in Alternatives 1 
through 5 and 9. This is a significant adverse 
impact. Alternatives 6 and 7 would support 
marginal populations while Alternative 8 would 
provide for adequate numbers. 

Riparian habitat occupies about 3 percent of the 
forest land base and is used by 88 percent of the 
terrestrial wildlife species. This crucial habitat 
would be adequately protected through the 
selection of Alternatives 6, 8 or 9. Selection of any 
other alternative would result in varying degrees of 
adverse impact to riparian habitat. Alternatives 1 
and 5 would result in significant adverse impacts 
to this habitat. 

Habitat removed by road construction is assumed 
to be permanently and irretrievably lost on those 
roads proposed as part of the permanent road 
system. The construction of new roads would lead 
to harassment of wildlife and reduce useable elk 
and large carnivore habitat within one-quarter mile 
of these roads. Planned road closures, if effective, 
would reduce this impact. 

Deer numbers are not expected to be greatly 
modified by any of the alternatives in the short 
term, but once commercial thinning dominates the 
harvest, beginning in the sixth decade, populations 
may be reduced. Because of different 
requirements, elk numbers would be influenced by 
many of the alternatives. The changes would be 
due to changing habitat conditions, new road 
construction, thinning and other habitat modifiers. 

No adverse impacts to elk are expected in the 
short term. Elk populations would in fact increase, 



77 



peaking in the second decade. In the long term, 30 
to 50 years hence, a gradual decline from second 
decade levels is expected for all alternatives 
except 8. The estimated population in 50 to 100 
years is expected to be 20 to 30 percent less than 
present levels for Alternatives 1 through 5, 7 and 9. 
Alternative 6 is expected to show a 5 percent 
decline, while Alternative 8 would result in no 
change. In the long term projected declines in elk 
production on Roseburg District lands may place 
additional demands for elk production on other 
federal lands including the Umpqua National 
Forest, which adjoins the east boundary of the 
Roseburg District. 

If it is assumed current fish populations reflect 
conditions and harvest regulations over the past 
decade, then itcan be assumed that fish 
populations would decline under Alternatives 1 
through 3 due to increased sedimentation. Fish 
would increase in Alternatives 4, 6, 7, 8 and 9 and 
remain the same under Alternative 5. The 
population changes cannot be quantified. 

The northern spotted owl is the only species listed 
by the State of Oregon as threatened that would 
be adversely impacted. The original 
recommendations of the Oregon Endangered 
Species Task Force influenced the proposed 
alternatives for the EIS area. Assuming that these 
recommendations identify minimum essential 
habitat, 18 of the 55 known owl pairs in the SYUs 
would be fully protected in the long term by 
Alternatives 3, 4 and 7, 19 pairs by Alternative 9, 25 
pairs by Alternative 6, and 55 pairs by Alternative 
8. A recent revision of the Task Force 
recommendations indicates that minimum habitat 
requirements may be greater. If so, Alternatives 6 
and 8 would provide habitat for 24 and 42 pairs 
respectively. No other alternative would support 
any owls in the long term. 

In all of western Oregon the combined BLM timber 
management decision for Medford and Coos Bay 
districts and the new preferred alternatives for the 
Eugene, Roseburg and Salem districts would come 
close to meeting the original Oregon Endangered 
Species Task Force recommendation for 
protection of the northern spotted owl. At the end 
of the first decade it is expected that all western 
Oregon BLM districts combined would maintain at 
least 90 pairs of owls, resulting from allocations 
made in land use plans and harvest scheduling. 

Cumulative adverse impacts are expected to be 
minimal in the short term. Habitat for an estimated 
78 of the recommended 90 pairs would be 
provided long-term protection through the land 
use planning process. In the long term a BLM 
shortfall in providing the recommended portion of 
owl pairs may result in a significant adverse impact 
to the species unless the unmet needs were 
reapportioned by the Oregon Endangered Species 
Task Force. 



Impacts on Recreation 

The impacts of timber management on 
recreation are related to changes in the physical 
setting. From the setting, recreationists derive 
different satisfactions, experiences and benefits. 
As changes in the setting affect experiences, levels 
and patterns of visitor use change. For example, in 
one area recreation use might be facilitated by 
road construction. In another area, visitation may 
show a long-term decline if the area's setting or 
resource availability is significantly altered. Some 
visitors may relocate to other areas where 
opportunities for desired experiences exist. 

Each alternative varies in approach and emphasis 
on meeting recreational needs. Some localized 
recreational demand would not be met if areas and 
facilities are not provided. The provision of areas 
and facilities for recreational pursuits would be 
beneficial since opportunities would be available 
to meet increasing demand (Chapter 2, Table 
2-13). 

As natural or natural-appearing environments are 
altered due to timber harvest, opportunities related 
to appreciation of the natural environment are 
reduced. Opportunities for such activities as 
camping, hiking, fishing, hunting, nature study and 
sightseeing would be degraded in some areas. The 
degree and magnitude of impact would be 
dependent upon the level of intensive timber 
management under each alternative. 

The alternatives provide for varying degrees of 
protection, use and maintenance of existing 
recreation sites. Generally, Alternatives 1 and 5 
have minimal or no provisions to preserve 
opportunities for additional recreation site 
development. Alternatives 2, 3, 4, 6, 7, 8 and 9 
allow for the protection of recreation development 
opportunities. Assuming these developments are 
realized, these alternatives would adequately meet 
increasing demand on public lands related to such 
activities as camping, picnicking, hiking, 
horseback riding, swimming and water-oriented 
use (see Appendix C, Table C-4). 

Clearcutting can enhance certain recreational 
activities such as hunting, collecting, berry 
picking, general sightseeing, picnicking and using 
ORVs by creating areas, improving access or 
providing openings for scenic views. The impacts 
of clearcutting would be most significant under 
Alternative 1 and moderately significant under 
Alternatives 2, 3, 4, 7 and 9. Alternatives 5 and 6 
call for levels of clearcutting similar to that under 
the existing situation. Under Alternative 8, 
clearcutting would be significantly less than under 
the existing situation. 

Many timber management activities create noise, 
odors, dust, fumes and additional traffic. Some 
recreational opportunities would be degraded by 



78 

these factors. However, many road-oriented 
dispersed recreationists indicate that impacts of 
timber management do not detract from their 
enjoyment (Downing and Clark 1979). 

Area-wide impacts to fishing and hunting success 
are dependent upon impacts to the species (see 
Impacts on Animals). In the short term, demand 
for hunting (see Table 2-13) would be met under 
all alternatives. In the long term, elk population 
decreases under all alternatives except 6 and 8 
(see Table 3-11) are expected to lead to decreased 
elk hunting opportunities and a corresponding 
reduction in hunter use. Declining fish populations 
under Alternatives 1, 2, 3 and 5 are expected to 
result in a similar reduction in fishing 
opportunities and related angler use (see Impacts 
to Animals, Conclusion). Decreased hunting and 
fishing opportunities could result in a relocation of 
these recreationists to other areas. 

Vehicular access would be improved as a result of 
new road construction. The beneficial and adverse 
impacts on recreation would be most apparent 
under Alternative 1 and least apparent under 
Alternative 8. 

Analysis of the sample 5-year timber sale plan 
indicates that slight reductions or increases in 
visitor use could occur at specific sites. Clearcut 
units near Severt Iverson County Park, Berry 
Creek Reservoir and Cavitt Creek County Park 
may create slightly adverse visual and auditory 
impacts which would degrade the recreation 
experience for some facility users. Harvest units in 
areas offering off-road vehicle opportunities 
(Yellow Creek Mountain, Hubbard Creek, 
Deadman Mountain) would not create significant 
adverse impacts but could result in slight 
increases in visitor use at these areas. 

Timber harvest in the vicinity of potential hiking 
and equestrian trails could degrade the recreation 
experience for most future trail users but could 
also provide clearings with scenic viewing 
opportunities. Such impacts could occur along 
potential trails in the following areas: Berry Creek, 
Tyee, North Umpqua-south side, Old Fairview, 
Silver Butte and White Rock. 

Environmental assessments which precede each 
timber sale will provide a site specific analysis of 
these potential impacts identified during the 
analysis of the sample timber sale plan. 

Impacts to potential national wild, scenic or 
recreational rivers will be further analyzed in the 
environmental assessments which precede each 
timber sale. If it is determined during site specific 
analysis that timber management actions could 
adversely affect potential suitability of those 
sections of the Umpqua or North Umpqua Rivers 
as components of the national wild and scenic 
rivers system, BLM would consult with the 
National Park Service to develop appropriate 



mitigation measures. There are no clearcut units in 
the sample 5-year timber sale plan within one- 
quarter mile of these river sections. 

Conclusions 

Visitor use increases or reductions may 
occur in certain areas as a result of impacts to 
specific recreation experiences. Alternatives 1 and 
5 would serve to adequately meet increasing 
demand for motorized recreational vehicle use and 
some dispersed use areas. However, under these 
alternatives, demand associated with many other 
activities (e.g., hunting, fishing, watersports and 
developed site use) would not be met due to a loss 
of development opportunities, degradation of the 
desired recreation experience and effects on 
recreation-related wildlife populations. 

Alternatives 2, 3, 4, 6, 7, 8 and 9 would serve to 
meet most recreational needs. In the long term, 
however, elk population decreases under all 
alternatives except 6 and 8 are expected to result 
in lower hunting success and a corresponding 
reduction in elk hunter use. Under Alternatives 1, 2 
and 3, some fishing demand would not be met 
because declining fish populations are expected to 
result in a lower fishing success and some 
decrease in related angler use. A lower desirability 
of BLM-administered lands for fishing and elk 
hunting could occur. 

The focus of Alternatives 6 and 8 is on dispersed 
activities, natural areas and protection of 
developed site opportunities in some areas. As a 
result, these alternatives would not be as 
responsive as Alternatives 2, 3, 4, 7 and 9 in 
meeting demand for hiking, horseback riding and 
off-road vehicle areas and trails. 

Impacts on Cultural 
Resources 

Complete area-wide field surveys of the SYUs 
to identify cultural sites have not been undertaken. 
However, complete cultural resource surveys will 
precede each specific timber management action 
that would result in ground disturbance or transfer 
of title (BLM Manual 8100, Cultural Resource 
Management). Under all alternatives, significant 
sites identified during these surveys would be 
protected in accordance with the National Historic 
Preservation Act of 1966 and Executive Order 
1 1593, as stated in the Code of Federal 
Regulations (36 CFR Part 800). 

Cultural resources not identified by intensive field 
survey could be inadvertently impacted under all 
alternatives. The potential for damage would be a 
function of the alternative's timber harvest level. 
Adverse impacts to such sites could occur through 
soil compaction, soil movement and/or chemical 
alteration by fire or mixing of organic matter. Soil 
compaction and soil movement could damage 



79 



artifacts and disrupt the internal structure of 
cultural deposits. If sites are uncovered, illegal 
artifact collecting could occur. A site's chemical 
alteration during slash disposal and site 
preparation could destroy combustible items, 
damage stone artifacts and contaminate carbon 14 
dating samples, making them unreliable for 
scientific analysis. 

The potential for damage from timber 
management activity to undiscovered sites would 
be greatest under Alternative 1 and least under 
Alternative 8. In a worst case, impacts would 
completely obliterate a site's remains. The 
potential for impacts would also be greater in 
areas of relatively high site density (e.g., Cow 
Creek, Camas Valley, Honey Creek-Susan Creek, 
Little River-Wolf Creek, Myrtle Creek, South 
Umpqua and White Rock-Dompier). 

Road construction would provide additional 
access to known cultural sites, resulting in 
increased visitation. Vandalism, theft and site 
erosion could result. Esthetic, recreational, 
interpretive and educational qualities of the sites 
could be degraded. Road construction and/or 
timber removal on slopes above sites could result 
in increased rates of erosion and soil slumpage 
onto sites. These adverse impacts would be most 
likely under Alternative 1 and least likely under 
Alternative 8. 

The landscape and vegetation surrounding a 
cultural site may be impacted by timber harvesting 
and road construction. Such impacts could reduce 
the site's esthetic appeal for recreation, 
interpretation and education. Impacts to the visual 
settings of cultural sites would be most likely 
under Alternative 1 and least likely under 
Alternative 8. Analysis indicates that the potential 
exists for visual setting impacts as a result of 
timber sales proposed in the sample 5-year timber 
sale plan. Site specific analyses of sales will be 
included in the environmental assessments which 
precede each timber management action. Should 
potential impacts to a site's setting integrity be 
identified, design art techniques and other 
constraints may serve to mitigate adverse impacts. 

Conclusions 

Appropriate measures would be taken to 
identify and protect cultural sites prior to ground- 
disturbing activities under all alternatives. 
Undiscovered cultural sites would be susceptible 
to damage from artifact breakage or destruction, 
displacement of materials and contamination of 
organic matter. Once a site is found, however, 
mitigation measures would be taken to minimize or 
avoid future damage. Under all alternatives, 
significant sites identified before logging would be 
managed to protect scientific and/or interpretive 
values. 



Impacts on Visual 
Resources 

Most timber management practices disrupt the 
land surface, change vegetative patterns, alter 
species composition, and thereby create visible 
contrasts (see Glossary) in the landscape. 
Assessing contrast for a proposed activity can 
indicate the severity of impact and help identify 
mitigation measures to reduce the contrast and 
meet VRM class objectives for an area (BLM 
Manual 8440). Environmental assessments will 
address site specific visual impacts and apply the 
Bureau's contrast rating system (see Glossary) to 
specific timber management actions. The severity 
of an impact on visual resources depends on such 
factors as landscape elements; location, number, 
size and shape of clearcut units; location and 
design of roads; yarding methods; amount and 
treatment of debris; and success of vegetative 
reestablishment in disturbed areas. 

Visual resource management (VRM) classes 
shown in Figure 2-3 were based on an inventory 
and evaluation of the area's scenic quality, 
sensitivity and distance zone (see Glossary). 
During the land use planning process, VRM 
classes as described in Chapter 2 may be changed 
to resolve conflicts between visual and other 
resources (BLM Manual 8411). Upgrading an 
area's recommended VRM class would provide 
adequate scenic value protection and result in 
beneficial impacts. Downgrading VRM classes 
increases the potential for adverse visual impacts. 
As an example, an area in the affected 
environment recommended as VRM Class II but 
subsequently managed as Class III or IV would 
receive less protection. Consequently, the long- 
term effect of downgrading might be to lower 
scenic quality in downgraded and adjacent areas 
even though the Bureau's ability to affect an area's 
overall scenic quality is often limited by 
intermingled land ownership patterns (see Figure 
1-1). In some cases the impacts of BLM timber 
management activities would be consistent with 
those on surrounding areas and would not create 
significant contrasts, but could tend to compound 
the degree of contrast by enlarging the scale of 
modification. 

Table 3-12 gives total acreage for each VRM class 
by alternative. Under Alternative 8, visual resource 
conditions (scenic quality) would improve. 
Adverse visual impacts in highly scenic and 
sensitive areas would not occur or would be 
mitigated. Under Alternative 6, most highly scenic 
and/or sensitive areas would be protected with 
slight adverse impacts occurring along some 
county roads, portions of the South Umpqua River, 
Little River, Rock Creek and Cow Creek drainages 
and public lands in the viewsheds of some rural 
residential areas. 



80 



Table 3-12 VRM Classes by Acreage 



VRM 


Affected 
Environment 1 






ALTERNATIVE 






Class 


1 


2,3,4,7,9 


5 


6 


8 


I 


30 


30 


30 


30 


30 


30 


II 


75,700 


2,400 


9,300 


1,100 


26,600 


75,700 


III 


22,900 


400 


13,600 


3,000 


22,400 


22,900 


IV 


325,370 


421,170 


401,070 


419,870 


374,970 


325,370 



Total 



424,000 



424,000 



424,000 



424,000 



424,000 



424,000 



1 VRM class acreage as recommended through the visual resource inventory and evaluation of the existing environment (see Figure 2-3) 



Table 3-13 Potential Impacts of the Sample 


Five-Year Timber Sale Plan on 


Visual Resources 






Clearcut 




Scenic 


Sensitivity 


Units 


VRM Class 1 Area 


Quality 2 


Level 3 


Within Area 4 


II Olalla Creek 


B 


H 


5 


Olalla 


B 


H 


1 


Cow Creek Road to Peck 


B 


H 


7 


Riddle 


C 


H 


7 


Garden Valley/Lookingglass 


B 


H 


6 


Tenmile 


B 


H 


2 


Berry Creek Reservoir 


A 


H 


4 


Camas Valley 


B 


H 


15 


Highway 38 (Pass Creek to Safley) 


B 


H 


3 


Coles Valley 


A 


H 


2 


Main Umpqua River 


A 


H 


5 


Pleasant Valley and I-5 


B 


H 


5 


Divide to Scotts Valley 


B 


H 


2 


Putnam Valley 


B 


H 


2 


Canyonville to Azalea 


B 


H 


7 


Riddle-Cow Creek Valley 


B 


H 


14 


Milo to East Boundary 


B 


H 


3 


Milo to Days Creek 


B 


H 


10 


Canyonville to Days Creek 


B 


H 


1 


South Myrtle Creek Drainage 


B 


H 


10 


North Myrtle 


B 


H 


5 


Dole 


B 


H 


6 


Wolf Creek Falls 


A 


H 


1 


Red Pond 


A 


H 


4 


Little River 


B 


H 


12 


Glide 


B 


H 


3 


North Umpqua River, Rock Creek 








to Boundary 


A 


H 


5 


Lower Rock Creek to Rock Creek 








Campground 


B 


H 


12 


III Reston 


B 


M 


4 


Drain-Yoncalla 


C 


M 


9 


Elkhead 


B 


M 


5 


Windy Gap (Smith River Road) 


B 


M 


3 


Smith River 


B 


M 


9 


South Myrtle Creek Drinage 


B 


M 


2 


North Myrtle 


B 


M 


3 


Buckhorn Road 


B 


M 


2 


Cavitt Creek 


B 


M 


12 


Driver Valley 


B 


L 


7 


Camas Swale and East Sutherlin 


C 


M 


5 


Nonpareil 


B 


M 


4 


' Recommended VRM class based upon an inventory and evaluation of the existing environment (see Figure 2-3) 




; Scenic quality (see Glossary) is keyed as A-high, B-moderate or C-low 








3 Sensitivity levels (see Glossary) are keyed as H-high, M-moderate or L-low. 








' All potential impacts listed would be in the FM-foreground/middleground distance zone (see Glossary) 







81 



Adverse visual impacts under Alternatives 2, 3, 4, 7 
and 9 would be low to moderate. Many highly 
scenic and/or sensitive areas would be protected. 
Attempts would be made to mitigate adverse 
impacts on all public lands. Protection would be 
afforded all State of Oregon designated scenic 
corridors (e.g., North Umpqua Highway 138, 
segments of Highways 42, 227 and Interstate 5), 
essential bald eagle habitat and recreation sites. 
Under Alternative 7 the intensive timber 
production base would be 72,128 acres less than 
under Alternatives 3 and 4 and 99,388 acres less 
than under Alternative 2. The withdrawal of this 
acreage would result in a lower level of timber 
harvest and consequently fewer impacts to visual 
resources than under Alternatives 2, 3, 4 and 9. 

Under Alternatives 1 and 5, adverse visual impacts 
would be high. Some protection would be 
provided for certain highly scenic and/or sensitive 
areas, primarily essential bald eagle habitat and 
existing recreation sites. 

Table 3-13 summarizes the potential visual impacts 
of the Original Proposed Action's sample 5-year 
timber sale plan. The table identifies the number of 
clearcut units in recommended VRM class II and 
III areas. The potential for impacts would be 
greatest in foreground-middleground areas with 
high scenic quality and high sensitivity. Following 
application of the contrast rating system, 
necessary mitigation measures would be 
identified. Depending upon VRM class objectives, 
possible mitigation measures under all alternatives 
except 1 include manipulating the size and shape 
of clearcut units, partial cutting, longer harvest 
cycles (see Table 1-3), screening with buffer strips, 
hydromulching road cuts and fills, complete debris 
disposal, replanting with a conifer mixture and 
other special techniques. Visual resources along 
some streams with high scenic quality and/or 
sensitivity may be adversely impacted since all 
alternatives except 6, 8 and 9 result in buffer entry 
for some timber harvest (see Table 3-5 and 
Appendix C, Table C-4). 

The adverse visual impacts of herbicide use would 
go unmitigated and would occur under all 
alternatives except Alternative 7. In the short term, 
vegetation sprayed with herbicides would create 
highly visible contrasts. In the long term, 
vegetative variety would be reduced as herbicides 
encourage conifers at the expense of other 
vegetation of high visual interest. Herbicides used 
on tall broadleaf species (madrone, oak, alder) 
cause long-term impacts of up to 20 years or until 
the dead vegetation is over-topped. Under all 
alternatives except 7 and 8, the impacts of 
herbicide use would be greater than under the 
existing situation (see Impacts on Vegetation). 



Impacts on Areas of Critical 
Environmental Concern 

Area of Critical Environmental Concern 
(ACEC) designation would improve management 
focus and provide guidelines to help achieve 
protection of important and relevant resource 
values. The alternatives vary in levels of ACEC 
designation. Some of the potential ACECs are also 
designated or proposed for other protective 
designation (see Table 2-14). 

Under Alternatives 6 and 8, seven areas (3,100 
acres) would be designated. Under Alternatives 2, 
3, 4, 7 and 9, four areas (2,100 acres) are identified 
for ACEC designation. Of the remaining three 
areas, two are currently designated Research 
Natural Areas (RNA) and one is proposed for RNA 
designation. Alternative 1 calls for ACEC 
designation in four areas (600 acres). Alternative 5 
has no provision for designation of ACECs. 

Table 3-14 identifies the level of ACEC designation 
and potential impacts to each area by alternative. 

Analysis of the sample 5-year timber sale plan 
indicates no sales would adversely impact those 
areas qualified for ACEC designation. 

Impacts on Special Areas 

Table 3-15 summarizes the potential impacts 
to areas with values which may warrant their 
designation as Research Natural Areas, 
Outstanding Natural Areas or Environmental 
Education Areas. Myrtle Island and Beatty Creek 
are currently Research Natural Areas and would 
not be adversely impacted under any alternative. 

Alternative 1 allows for designation of those areas 
which would not affect the commercial timber 
production base of the SYUs. Alternatives 2, 3, 4, 7 
and 9 allow for designation of those areas 
identified as having significant natural values for 
science, recreation or education. Alternative 5 
provides no additional natural area designation. 
Alternatives 6 and 8 emphasize the study and 
designation of natural areas. However, some sites 
(e.g., Red Pond, Dompier Creek Landslide) with 
natural or environmental education values may be 
adversely impacted if they are not designated or 
do not receive other protective management. 

Analysis of the sample 5-year timber sale plan 
indicates that no areas with known or suspected 
natural values would be impacted. 

Impacts on Energy Use 

Table 3-16 indicates the annual energy 
investment required by alternative, as expressed in 
British thermal units (Btu's - see Glossary). 



82 



Table 3-14 Potential Impacts to Areas Qualified for ACEC Designation 



ALTERNATIVE 



Area Qualified for 
ACEC Designation 

1. Brad's Creek 

2. Golden Bar 

3. North Umpqua River 

4. Tater Hill 

5. Myrtle Island RNA 

6. Beatty Creek RNA 

7. North Myrtle Creek 
(Slideover) 

Total ACEC Acreage by 
Alternative 



1 


2,3,4,7,9 


5 


6,8 








_ 











- 





- 





- 





- 


1 


- 





























- 


1 


- 






600 



2,100 



3,100 



= No impact - = Adverse impact 

' Area is proposed for Research Natural Area designation which would protect the area's significant resource values. 

Table 3-15 Potential Impacts to Special Areas 





Potential 


Area 


Designation 1 


Tater Hill 2 


RNA 


North Myrtle Creek 2 


RNA 


(Slideover) 




Woodruff Canyon Lands 


RNA 


Old Fairview 


RNA 


Little River Arch 


ONA 


Red Pond 


EEA 


Dompier Creek Landslide 


ONA 



ALTERNATIVE 



2,3,4,7,9 












































- 



= No impact - = Adverse impact 

' Key for potential designation: RNA - Research Natural Area, ONA -Outstanding Natural Area, EEA - Environmental Education 

Area. 

7 Impacts to this area are further examined in the preceding section on Impacts to Areas of Critical Environmental Concern. 



It is assumed that all energy consumed would be 
in the form of fossil fuels or derivatives, and any 
energy investment would constitute an 
irretrievable reduction of world supplies of 
petroleum-derived energy. The majority of energy 
consumed is attributable to road development and 
care and log production (all actions taken to 
harvest trees and get logs to the mill). 

If the 716 billion Btu's attributable to the New 
Preferred Alternative were all expended in the form 
of gasoline, it would equate to 5.7 million gallons 
or about 0.4 percent of the 1.3 billion gallons of 
gasoline consumed in Oregon in 1980. This energy 
investment is insignificant if compared to the 
projected 1980 Oregon total of 581 trillion Btu's 
(Oregon Department of Energy 1980). 



Impacts to Human Health 

The possibility of human health being 
impacted by the use of herbicides is related to the 
toxicity of the herbicide, the likelihood of exposure 
and resulting dosage received (Norris 1975). While 
there are no chemicals that are non-toxic, a 
substance of moderate or high toxicity may 
represent no significant hazard if exposure is very 
low, just as a relatively non-toxic agent may be 
harmful if exposure is extensive and long term. 
Herbicides proposed for use in the SYUs are given 
in Table 1-4 and their toxicities and activities are 
given in Table 3-17. 



83 



Table 3-16 Estimated Annual Energy Consumption 

ALTERNATIVE 


12 3 4 5 6 7 

Energy Consumption 

(Billion Btu's) 834 770 741 723 528 536 514 


8 

218 


9 

716 



Table 3-17 Herbicide Toxicity 








Common 
Name 


Acute Toxicity 
LD 50 1 Commonly Used 
(Rats) Term 2 


Activity in 
the Soil 


No Effect 

Level Dose 

in (mg/Kg/day) 


Tolerances for 

Residues in or 

on Foodstuffs 

(40 CFR Part 180) 


Asulam 
(Asulox) 


8,000 mg/kg 


practically 
non-toxic 


short persistence— 
half-life 6 to 14 days. 


(not available) 


100 ppb 


Atrazine 


3,080 mg/kg 


slightly toxic 


absorbed on muck 
or clay — remains in 
1 foot of soil. 


200 
(Reproductive 3 ) 


20-250 ppb 


2,4-D 


300-1,000 
mg/kg 


moderately toxic 
to slightly toxic 


leached in sandy 
soils, breakdown 
depends on microbial 
activity. 


20 (Reproductive) 
20 (Teratogenic 4 ) 


100-500 ppb 


Dalapon 
(Dowpon) 


7,570 mg/kg 
(female) 
9,330 mg/kg 
(male) 


practically non- 
toxic 
500 (Teratogenic) 


leaches readily in 
soil, breakdown rapid 
and complete. 


50-150 
(Reproductive) 


100-10,000 ppb 


Fosamine 
(Krenite) 


24,400 mg/kg 


relatively 
harmless 


rapid degradation- 
very little movement. 


60 (Reproductive) 
600 (Teratogenic) 


(non listed) 


Glyphosate 
(Roundup) 


4,320- 
4,900 mg/kg 


slightly toxic 


strong absorption- 
very little or no 
leaching. 


30 (Reproductive) 
30 (Teratogenic) 


100-6,000 pbb 


Hexazinone 
(Velpar) 


1,690 mg/kg 


slightly toxic 


half-life 2 to 6 
months in silt loams. 


60 (Reproductive) 
300 (Teratogenic) 


100-200 ppb 


Picloram 
(Tordon) 


8,200 mg/kg 


practically 
non-toxic 


sorption by organic 
matter and clays, 
may leach in sandy 
soils. 


80-150 

(Reproductive) 
1,000 
(Teratogenic) 


50-500 ppb 


Triclopyr 
(Garlon) 


2,140- 
2,830 mg/kg 


slightly toxic 


possible leaching, 
half-life of 46 day. 


30 (Reproductive) 
200 (Teratogenic) 


(non listed) 


' LD 50 (Lethal Dose 50) is the dose of a substance that is fatal to 50 percent of the test animals. Also known as median lethal dose. 

2 Moderately toxic is 50-500 mg/kg, slightly toxic is 500-5,000 mg/kg; practically non-toxic is 5,000-15,000 mg/kg; relatively 
harmless is more than 15,000 mg/kg in a single oral dose to rats 

3 The highest dosage level at which no effects have been observed in test animals including loss of skin, hair, reduced litter size, or 
general lethal toxicity 

4 Fetus malformations during development, not associated with genetic change. 



84 



In general, exposure of humans to herbicides can 
occur in two ways: directly, by occupational 
means, or indirectly by environmental means. The 
number of persons that could be affected by 
herbicide application in the EIS area is very small. 
Planned application techniques have been shown 
to effectively reduce or prevent spray from drifting 
onto streams and water bodies. Posting of sprayed 
areas should effectively minimize involuntary 
exposure to forest users. 

All herbicides proposed for use in the RSYUs are 
registered with the Environmental Protection 
Agency (EPA). Extensive studies of the absorption, 
distribution, metabolism and excretion of 
herbicides in animals have shown that herbicides 
and their metabolites are rapidly eliminated from 
tissues of most animals (including humans) and 
thus do not accumulate to harmful levels 
(Eligehausen et al. 1980, Lavy et al. 1982, Leng et 
al. 1982, Nash et al. 1982, Newton and Norris 1968, 
Norris et al. 1974, Sikka et al. 1977, and Wolfe 
1976). There is no evidence of carcinogenic effects 
for any of the herbicides listed in Table 3-17. With 
respect to 2,4-D, Picloram, Glyphosate, Atrazine 
and Fosamine, some additional direct data are 
needed to assure certitude. The laboratory 
dosages at which potential reproductive effects 
have been detected or at which carcinogenic and 
mutagenic effects have been sought are much 
greater in concentration and duration than any 
exposure that could occur in the forest as a result 
of vegetation control treatments. Because of the 
limited toxicity of the herbicides and the low 
potential for exposure, the likelihood of an adverse 
impact on human health is negligible. 

Impacts on Socioeconomic 
Conditions 

The socioeconomic impacts are presented here 
for two different bases as a means of 
differentiating between the effects of potential 
timber management programs on existing 
socioeconomic conditions and their effects on the 
conditions expected to occur if the current timber 
management program were continued. The 
program manager must know how future 
conditions would be affected if the program were 
changed. The public is generally most concerned 
with how future conditions would differ from 
existing conditions. The impacts are presented 
mainly in table form, as changes measured from 
the existing condition and as changes measured 
from the no action condition— the condition 
expected if the current program were continued. 
The average 12-month harvest from the Roseburg 
District from 1976 to 1980 was 187.5 MM bd. ft. 
This recent experience is the baseline labeled the 
existing condition. The no action alternative, 201 
MM bd. ft. per year, is the level which would have 
prevailed if the decadal allowable harvest (2,010 
MM bd. ft.) had been sold and harvested in 



constant annual increments. The average level of 
actual sales for 1976-1980 was 197.1 MM bd. ft. 
and for 1972-1975 was 208.9 MM bd. ft. 

Table 3-18 shows projections representing average 
local employment and earnings potential of timber 
sales under all alternatives during the first decade 
after implementation. Impacts on employment and 
earnings would be phased in over a period of 2 or 
3 years due to the customary time lag between 
sale and harvest. Impacts on receipts distribution 
would be delayed an additional year. The 
projections represent the local employment and 
earnings which would be realized if the annual 
volume sold under each alternative is promptly 
harvested and processed. 

While it is anticipated that labor productivity will 
increase in future years, leading to fewer jobs per 
unit of primary timber processed (Wall and Oswald 
1979). In order to simplify impact estimates, they 
have not been adjusted to reflect productivity 
changes. The effect of this simplification is to 
overstate the impacts on employment and 
earnings by about 10 percent in the short term, 
and by greater amounts in the long term. 

Tables 3-19 and 3-20 focus on the impacts each 
alternative is projected to have on public revenue. 
Recently, Roseburg District's timber sale program 
has experienced wide swings in bid prices for 
stumpage. For example, in FY 1981 the average 
price of timber sold was $260 per M bd. ft.; 
however, in FY 1982 the district recorded an 
average sale price of $94 per M bd. ft. Given this 
volatility, tables 3-19 and 3-20 array possible 
impacts on public revenue against two baseline 
harvest levels and two levels of receipts. If FY 1981 
sale values are the average for period 1984 - 1993, 
then average annual disbursements to O&C 
counties from the SYUs are projected to range 
from $36.2 million in Alternative 1 to $10.5 million 
in Alternative 8 (Table 3-19). When compared to 
the no action condition, Douglas County receipts 
from the harvest of timber on O&C lands in the 
Roseburg District could decline by $.5 million in 
Alternative 1 or by as much as $2.5 million in 
Alternative 8, if FY 1982 sales values are the 
average for the next 10 years. The average annual 
disbursement of severance tax receipts from 
CBWR lands to seven tax districts in Douglas 
County is projected to range from $122,100 in 
Alternative 1 to $35,500 in Alternative 8, if FY 1981 
sales conditions prevail. Again, compared to a 
maintenance of the no action level, Alternative 1 
would yield an average annual decline in 
severance tax receipts of $7,200 while Alternative 8 
would yield $38,500 less if the district only 
averages $94 per M bd. ft. over the next decade. 
Historically, the sale of timber on public domain 
lands in the Roseburg District has accounted for 
roughly 1 percent of the district's total receipts 
from the sale of timber. Assuming that percentage 
were maintained in all alternatives, Oregon's 



85 



Table 3-18 Short-Term Impacts Compared to No Action (and Existing) 
Condition on Local Employment and Earnings Related to Timber Harvest 
(Average annual amounts during first decade) 






Timber 


ndustry Employment (Jobs) 






Total Employment (Jobs) 






Total Earnings 
(Millions ol 1977 dollars 






Logging and 


Processing 




Forest 
Management 


Douglas County 


Total for 
Regional Economy 


Dougt 


is County 


Total for 
Regional Economy 


Dough 


s County 


Total tor 
Regional Economy 


Douglas 
County 




No 
Action 


Existing 


No 
Action 


Existing 


No 
Action 


Existing 


No 
Action 


Existing 


Action 


No 
Existing 


Action 


No 
Existing 


Action 


No 
Existing 


Alt 1 (Max Tbr ) 
Alt 2 (Emp Tbr ) 
Alt 3 (Low MHS) 
Alt. 4 (OPA) 
Alt 5 (No Action) 
Alt 6 (HD) 
Alt 7 (No Herb ) 
Alt 8 (Full eco ) 
Alt. 9(NPA) 


'519 
+389 
♦325 
♦283 

-106 
-148 
-690 

♦271 


(•599) 
(♦469) 
(♦404) 
(•363) 
(+ 80) 
(- 27) 
(- 68) 
(-611) 
(♦351) 


♦651 
♦488 
♦407 
•355 

-133 
-185 
-866 
♦340 


(♦751) 
(♦588) 
(♦507) 
(•455) 
(♦100) 
(- 33) 
(- 85) 
(-766) 
(♦440) 


•18 

• 15 

• 11 

• 9 

- 4 

- 5 
-24 

• 9 


(♦21) 
(•16) 
(•14) 
( + 12) 
(♦ 3) 
i- D 
(- 2) 
(-21) 
(♦12) 


•1.135 

• 851 
+ 710 

• 619 

- 232 

- 323 
-1.509 

• 593 


(♦1.309) 
(♦$120) 
(• 884) 
(♦ 793) 

I' 17-1) 
(- 58) 
(- 148) 
(-1,335) 
(♦ 767) 


•1.514 
♦1.135 
+ 946 

• 826 

- 310 

- 430 
-2.012 

• 791 


•1,746) 
♦1,367) 
+ 1.178) 
♦1,058) 
• 232) 

- 77) 

- 198) 
-1.780) 
♦1.023) 


•$133 
•S100 
•$8 3 
♦S 7 2 

-$2 7 

-S 38 

$17 7 

♦$6 9 


(♦$15 3) 
(♦$120) 
(+$103) 
(♦$ 9 3) 
(•$ 20) 
(-$ 7) 
(-$ 17) 
(-$15 6) 
(♦$ 90) 


•$184 
♦S138 
+$11. S 
•$10.0 

-$ 3 8 
-$ 52 

-$245 
♦$ 9.6 


(•$21 2) 
(♦$166) 
(♦$143) 
(+$12 9) 
(•$ 28) 
(-$ 9) 
(-$2 4) 
(-$21 6) 
(•$124) 


Employment and 
earnings dependent on 
the No Action 
(Existing Condition) 
harvest level 201 
(187 5) MMbd tt/year 


1.186 


(1,106) 


1,487 


(1,388) 


41 


(38) 


2.593 


(2.419) 


3,457 


(3.225) 


$30 3 


($28 3) 


$42 


($392) 


Average of all sources 
in county and region 
1977-1980 (Tables 2- 
17 & 2-18) 


8.500 


(8500) 


35.100 


(35.100) 


NA 


(NA) 


35.000 


(35.000) 


246,300 (246.300) 


$493 5 


($493 5) 


$3,073.5 


($3,073.5) 


Percent of Roseburg 
BLM of county and 
regional average 1977- 
1980 


1 4 0% 


(13 0%) 


4 2% 


(4 0%) 


NA 


(NA) 


74% 


(6.9%) 


1 4% 


(13%) 


6 1% 


(57%) 


I 4% 


(1.3%) 


NA Estimates of < 


;ounty totals are not available. 























annual receipts from public domain revenues from 
the district would vary from $30,100 in Alternative 
1 to $8,700 in Alternative 8 under the FY 1981 sales 
average of $260 per M bd. ft. 

In comparison to a continuation of the harvest 
levels which prevailed from 1976 to 1980 (existing 
condition), Alternatives 1 through 5 and 9 all 
increase employment and personal earnings 
dependent on the harvest of timber from public 
lands administered by the Roseburg District. In 
contrast, Alternatives 6 through 8 yield lower 
levels. Employment and income changes related to 
fishing, hunting and other recreation are expected 
to be insignificant for the short term. In the long 
term, slight declines in fishing would occur in 
Alternatives 1-3 and slight declines in hunting 
would occur in all alternatives except 6 and 8. 
Relative to Alternative 4, Alternative 3 emphasizes 
current benefits at the expense of increased timber 
production beginning 140 years from now. See the 
Impacts to Vegetation, Conclusions, discussion. 

Clearcutting and the use of herbicides would 
continue to be controversial due to concerns of 
some residents, particularly adjacent landowners, 
about ecosystem damage or health damage as 
opposed to the concerns of other residents for 
economic benefits in timber production. 
Alternatives calling for rates of clearcutting higher 
than under the existing plan would be perceived 



by some persons as increasing the risk of 
downstream damage from flooding and washouts. 
Another perception of some residents is that 
increased timber harvest levels would decrease the 
level of low summer water flows. The impacts on 
personal and community concerns of specific 
actions such as timber sales and herbicide 
application would depend in part on the locations 
of the activities as well as on the manner in which 
BLM communicates with affected residents. 

As shown in the survey cited in Table 2-27, more 
residents of southern Oregon favor increased 
timber production than favor increased hunting 
and fishing or wildlife habitat. Although the net 
impact of these concerns is difficult to assess-- 
depending on the intensity of the concern, the 
knowledge of the holder and the specific 
alternatives being compared—it is likely that an 
alternative that reduced BLM timber sales would 
not be favored by a majority of southern Oregon 
residents. Concerns for economic welfare and its 
relation to dependency on timber harvest have 
undoubtedly deepened since the survey as a result 
of the current recession. 

Conclusions 

As noted in Chapter 2, the regional economy 
is tightly linked to wood products employment. 
The currently depressed levels of employment in 
that sector are related to demand conditions in the 



86 



Table 3-19 Projected Distribution of O&C Payments from SYUs to Counties 


by Alternative 










(Average annual disbursements in millions of dollars, 1984-1993) 






Alt. 1 Alt. 2 Alt. 3 


Alt. 4 


Alt. 5 Alt. 6 Alt. 7 Alt. 8 


Alt. 9 




Max.Tbr. Emp.Tbr. Low MHS 


OPA 


No Action HD No Herb. Full Eco. 


NPA 


Total O&C Disbursements 1 










Douglas County @$ 94/M bd. ft. 


3.3 3.0 2.9 


2.8 


2.3 2.1 2.0 1.0 


2.8 


@$260/M bd. ft. 


9.1 8.4 8.0 


7.8 


6.3 5.7 55 26 


7.8 


All Oregon Counties 










receiving O&C @$ 94/M bd. ft. 


13.1 121 11.6 


11.3 


9.1 8.3 8.0 3.8 


11.2 


disbursements @$260/M bd. ft. 


36.2 33.5 32.1 


31.2 


25.2 22.9 22.1 10.5 


31.0 


Change in O&C Disbursements Compared to Existing Conditions (187.5 MM bd. ft. per year) 2 




Douglas Gounty @$ 94/M bd. ft. 


- 0.2 - 0.5 - 0.6 


- 0.7 


- 1.2 - 1.4 - 1.5 - 2.5 


- 7 


@$260/M bd. ft. 


+ 5.6 + 4.9 + 4.5 


+ 4.3 


+ 2.8 + 2.2 + 2.0 - 0.9 


+ 4.3 


All Oregon 










Counties 










receiving O&C @$ 94/M bd. ft 


- 1.1 - 2.1 - 2.6 


- 2.9 


- 5.1 - 5.9 - 6.2 -10.4 


- 3.0 


disbursements @$260/M bd. ft. 


+22.0 +19.3 +17.9 


+ 17.0 


+ 110 + 8.7 + 7.9 - 3.7 


+ 16.8 


Change in O&C Disbursements Compared to the No Action Condition (201 MM bd. ft. per year) 3 




Douglas County (5)5 94/M bd. ft. 


- 0.5 - 0.8 - 0.9 


- 1.0 


- 1.5 - 1.7 - 1.8 - 2.8 


- 1.0 


@S260/M bd. ft. 


+ 5.3 + 4.6 + 4.2 


+ 4.0 


+ 25 + 1.9 + 1.7 - 1.2 


+ 4.0 


All Oregon 










Counties 










receiving O&C @$ 94/M bd. ft. 


- 2.1 - 3.1 - 3.6 


- 3.9 


- 6.1 - 6.9 - 7.2 -11.4 


- 4.0 


disbursements @$260/M bd. ft. 


+21.0 +18.3 +16.9 


+ 16.0 


+ 10.0 + 7.7 + 6.9 - 4.7 


+ 15.8 


' $94/M bd. ft. is the average value of tim 


ber sold by the District in FY 1982. $260/M bd. ft. is the average value of timber sold by the 


District in FY 1981. All calculations assume that in each alternative a constant 3.6 


percent of the annual harvest would be from 


CBWRand PD land. 










'' The range of projected total O&C disbi 


jrsements is contrasted against the existing conditions baseline established in table 2-24, 


DEIS. (187.5 MM bd. ft. per year times 96.4% O&C times $157 per M bd. ft.] 


I 






•' The range of projected total O&C disbursements is contrasted against the no action condition harvest level times the 1976-1980 


average receipts per M bd. ft. ($157) times percentage O&C harvest. 









Table 3-20 Projected Distribution of Severance Taxes on CBWR Lands by 

Alternative 

(Average Annual Disbursements in thousands of dollars, 1984-1993) 1 - 2 





Alt.1 
Max. Tbr. 


Alt. 2 
Emp. Tbr. 


Alt. 3 
Low MHS 


Alt. 4 
OPA 


Alt.5 
No Action 


Alt. 6 
HD 


Alt. 7 
No Herb. 


Alt. 8 
Full Eco. 


Alt. 9 
NPA 


@$94/M bd. ft. 
@$260/M bd. ft. 


44.1 
122.1 


40.8 
112.8 


39.1 
108.2 


38.0 
105.2 


30.7 
84.9 


28.0 
77.3 


26.9 
74.4 


12.8 
355 


37.7 
104.4 



Change in Severance Tax Distribution Compared to Existing Condition 
(187.5 MM bd. ft. per year) 



@$ 94/M bd. ft. 


- 3.7 


- 7.0 


- 8.7 


- 9.8 


-17.1 


-19.8 


-20.9 


-35.0 


-10.1 


@$260/M bd. ft. 


+ 74.3 


+65.0 


+60.4 


+57.4 


+37.1 


+29.5 


+ 26.6 


-12.3 


-566 



Change in Severance Tax Distribution Compared to No Action Condition 
(201 MM bd. ft. per year) 



@$94/M bd. ft. 


- 7.2 


-10.5 


-12.2 


-133 


-20.6 


-233 


-24.4 


-38.5 


-13.6 


@$260/M bd. ft. 


+ 70.8 


+61.5 


+56.9 


+ 53.9 


+33.6 


+26.0 


+ 23.1 


-158 


+53.1 



' At present, the district sells approximately 5.1 MM bd. ft. of timber from CBWR lands each year. The impacts displayed in this table 
assume that the District will continue to obtain roughly 2.5 percent of its annual cut from CBWR lands. Property taxes paid would 
not vary by alternative. 

'' The seven tax districts in Douglas County which share the severance tax distribution are Douglas County, Umpqua Community 
College, Douglas Education Service District, and the Oakland, Camas Valley. Winston Dillard and Roseburg School Districts. See 
Table 2-21 for the distribution of taxes from CBWR lands in recent years. 



87 



national economy. Beneath today's concerns are 
projections for a dip in wood products production 
in the 1980's and 1990's due to the availability of 
timber. Alternatives 1 through 4 and 9 increase 
timber supply from the district and therefore would 
mitigate dips in employment projected to occur 
independent of actions by BLM. Alternatives 6 
through 8 reduce local timber supply and would 
intensify the projected downturn. If timber job 
losses were associated with a mill closure, workers 
in the core work force would be unemployed. 
Older workers might not be able to obtain new 
jobs. The personal losses would be great for those 
individuals deprived of their functional relationship 
to society. 



89 



Chapter 4 Consultation and 
Coordination on the Draft 
Environmental Impact 
Statement 




The Draft Roseburg Timber Management 
Environmental Impact Statement (Interior DEIS 
82-27) was filed with Environmental Protection 
Agency and released to the public on June 22, 
1982 and open to comment until August 23, 1982. 

A public hearing on the draft was held August 18, 
1982 in Roseburg, Oregon. Oral testimony was 
presented by five people in the afternoon session 
and by 14 people in the evening session. 

A total of 95 letters were received in response to 
the draft environmental impact statement. These 
are listed in the order received in the Response to 
Written Comments section. Substantive comments 
were identified in 29 letters and they, together with 
responses, are printed on the following pages. 
Copies of all comment letters and the hearing 
transcripts are available for review in the Oregon 
State Office, 825 N.E. Multnomah Street, Portland, 
Oregon and Roseburg District Office, 777 N.W. 
Garden Valley Blvd., Roseburg, Oregon. 

All letters and hearing testimony were reviewed 
and considered. Comments that presented new 
data, questioned facts on the adequacy of the 
impact analysis, or raised questions or issues 
bearing directly on the draft EIS are responded to 
in this final EIS. Some persons both testified orally 
and submitted written comments, resulting in 
duplication of comments. These comments are 
responded to in Response to Written Comments. 



90 

Several reviewers made various resource 
management recommendations. These 
recommendations, as well as all public input, will 
be considered before the final decision is made. 

Consultation and coordination also took place 
with many Federal and State agencies and local 
governments. Most extensive were coordination 
efforts with the following: USFS, Umpqua National 
Forest, Oregon Department of Forestry, and 
Oregon Department of Fish and Wildlife. 

Response to Comments 
Common Issues 

Five broad issues were raised frequently by 
reviewers. These issues and responses to them are 
presented below. 

Common Issue 1: Wildlife impacts largely dwell on 
possible long-term effects and not the period of 
the 10-year plan. Adequate old growth would be 
available after one decade not to affect 
populations of many wildlife species regardless of 
alternative. 

Response: The text has been revised in the FEIS, 
Chapter 3, Impacts on Animals section, to include 
additional discussion regarding short-term 
impacts on wildlife. 

Common Issue 2: In this economic climate how 
can you be certain of the indicated level of 
funding necessary to implement the intensive 
management practices? Please display a variety of 
funding levels for each alternative. 

Response: The district's choice of a Preferred 
Alternative is based on factors other than funding 
(see Appendix A). The following table shows 



various levels of budget and volume offered for 
sale for the Preferred Alternative (Alternative 9). 

Common Issue 3: The DEIS does not provide 
sufficient detail on the level of intensive 
management practices proposed for each 
alternative. Please display this information as well 
as the proportion of harvest attributable to each 
practice. 

Response: The following table displays 
contributions to the allowable cut associated with 
each intensive management practice for 
Alternatives 4 and 9. 

Contribution 
to Annual Harvest 





Alt. 4 


Alt. 9 




(OPA) 


(NPA) 


Intensive Management Practice 


MM bd. ft. 


MM bd. ft. 


Intensive Base 






Harvest and Reforestation 


183.0 


183.1 


Precommercial/ 






Commercial Thinning 


26.0 


26.0 


Fertilization 


12.2 


12.2 


Tree Improvement 


19.1 


19.1 


Sub Total 


240.3 


240.4 


Constrained Base 






Harvest and Reforestation 


9.1 


6.3 


Total 


249.4 


246.7 



Alt. 9 (NPA) at Varying Funding Levels 
(in thousands of dollars) 

Full Program With 





Full 


No. 


No. PCT 


Major Program Area 1 


Program 


Fert. 


or Fert. 


Transportation Systems 2 


$1,683.0 


$1,599.9 


$1,422.7 


Timber Management 


7,120.9 


6,419.5 


5,414.6 


Fire Management 3 


525.1 


499.1 


443.8 


Wildlife 


128.0 


128.0 


128.0 


Soil, Air, Water 


100.0 


100.0 


100.0 


Total 


$9,557.0 


$8,746.5 


$7,509.1 


Allowable Cut Level MM bd. ft. 


247 


235 


209 



' Program areas directly related to harvesting or reforestation and growth 

2 This does not include funding for bridge, road, and aggregate production projects handled through the Federal Highway Administration. 
Funds for these projects are held at the State Office. An additional $500,000 is needed for these construction projects. 

3 Program areas directly related to reforestation and growth. 



91 



Common Issue 4: The DEIS does not provide 
sufficient detail on forest production opportunities 
foregone by various allocations by alternative. 

Response: The following table displays timber 
volume foregone for each EIS alternative by land 
use allocation category. 



Timber Volume Foregone in Allocation Areas 

Million Board Feet Production/Year, Scribner (MM bd. ft./Yr.) 



El S 

3 



ALTERNATIVE 

4 5 6 



.5 

.5 

.5 

2.5 



4.0 



.5 

.5 

.9 

2.5 

.5 



4.9 



.5 
.5 
.9 
2.5 
.5 



49 



.5 
.5 
.9 
2.5 
.5 



4.9 



Land Use Allocation 
Category 

No Planned Harvest Areas 

Botanical 

Cultural 

Recreation 

Bald Eagle 

Golden Eagle & Raptor 

Old Growth Blocks 

Riparian Areas 

Sub-Total Volume Foregone 

Constrained Harvest Areas 

VRM II 

Bald Eagle 

Northern Spotted Owl 

80-Acre Blocks 

Old Growth Blocks 

Osprey/Heron 

Mid-age & Old Growth- 

Riparian 

Sub-Total Volume Foregone 

Minimum Harvest Age 
Constraint on 
Intensive Base 

No Use of Herbicides, 
Fertilizers or 
Computed Genetic Gain 

Total Timber Volume 

Foregone 
Allowable Cut Level 

1 Alternative 5 utilizes the 1970 land base, inventory and allowable cut projections. 

? For these alternatives, mid-age and old growth allocations managed under modified area control includes: VRM II, Northern Spotted 
Owl, and osprey/heron habitat. 



3.7 2 


22.0 2 


22.0 : 


10.4 


10.1 


10.1 


14.1 


32.1 


32.1 



.5 


.5 


.5 


.5 


.5 


.5 


.5 


.5 


1.8 


.9 


2.9 


.9 




2.5 




2.3 


1.0 


.5 


1.9 


0.5 


13.8 




22.8 




20.5 




68.0 


12.2 


38.1 


4.9 


96.6 


16.9 


10.5 




21.6 




1.6 




4.1 


C 


8.0 




14.0 




46.0 




46.4 




1.1 




.7 




54.0 


22.0 2 
10.1 


60.4 


22. 3 : 


67.2 


32.1 


86.8 


22.3 



7.0 



7.0 



4.7 



80.0 



25.6 



7.0 



4 


26 


37 


44 


1 


110 


117 


209 


46 


289 


267 


256 


249 


201' 


183 


176 


84 


247 



92 

Common Issue 5: Several respondents reacted to 
data displayed in Table B-6 of the DEIS, which is 
shown below. Particular concern was expressed 
over the magnitude of the district's average 
management costs per acre in the first years of 
reforestation. 



Baseline Yields, Costs and Revenues 
(MCF, Dollars Per Acre) 



Douglas Sustained Yield Unit 

Full Intensive Management Regime: Plant improved stock, precommercially thin where needed, 
commercially thin at ages 35 and 55, fertilize at ages 12, 35, 45, 55, 65 and final harvest at age 75. 







Expected 


Diameter 




Gross 


Logging 


Hauling 


Estimated 


BLM 




Age 


of 


Volume 


of 


Pond Value 


Revenue 


Cost 


Cost 


Sales Values 


Management 


t 


Stand 


MCF/Acre 


Harvest 


Per MCF 


Per Acre 


Per Acre 


Per Acre 


Per Acre 


Costs 























557 95 


Site prep , plant, protect 


1 


















50 54 


Replant, protect 


2 


















50 54 


Replant, protect 


7 


















1607 


Release 


12 


















1372 


Precommercially thin & fertilize 


35 


















361.09 


Commercially thin & fertilize 


45 


















71 64 


Fertilize 


55 


















361 09 


Commerically thin & fertilize 


65 


















71 64 


Fertilize 


75 


















28945 


Final harvest 


'35 




1.068 


10.34 


742 08 


792 54 


88663 


125 16 


-21925 






55 




2.734 


12 78 


914 86 


2501.23 


1310.23 


320 42 


870.57 






75 




9,129 


2042 


1455.85 


13290 46 


1877,12 


1069 91 


10343,41 






35 




1.068 


10,34 


1385 56 


1479.78 


886 63 


125.16 


467,97 






55 




2.734 


1278 


244052 


667239 


131023 


32042 


5041,73 






75 




9,129 


20 42 


554880 


50655 08 


1877.12 


1069 91 


47708 03 







South Umpqua Sustained Yield Unit 

Full Intensive Management Regime: Plant improved stock, precommercially thin where needed at age 
15, commercially thin at ages 45 and 65, fertilize at ages 15, 45, 55, 65, 75 and final harvest at age 85. 





Expected 


Diameter 




Gross 


Logging 


Hauling 


Estimated 


BLM 




Age of 


Volume 


of 


Pond Value 


Revenue 


Cost 


Cost 


Sales Values 


Management 




Stand 


MCF/Acre 




Harvest 


Per MCF 


Per Acre 


Per Acre 


Per Acre 


Per Acre 


Costs 

557.95 


Site Prep , plant, protect 


1 
















50 54 


Replant, protect 


2 
















50 54 


Replant, protect 


7 
















16 07 


Release 


I.' 
















137.2 


Precommercially thin & fertilize 


45 
















361.09 


Commercially thin & fertilize 


55 
















71.64 


Fertilize 


65 
















361 09 


Commercially thin & fertilize 


75 
















71.64 


Fertilize 


85 
















28945 


Final harvest 


'45 


1.754 


11.58 


829 88 


1455,62 


107509 


20556 


174 96 






65 


2,108 


1374 


98283 


2071.82 


1035.39 


247.05 


789 36 






85 


8.811 


20 40 


1454,43 


1281502 


183344 


103264 


9948 92 






45 


1,754 


11 58 


1852.12 


3248 62 


107509 


20556 


1967.96 






65 


2,108 


13.74 


3078 50 


6489 49 


1035 39 


247 05 


5207 03 






85 


8.811 


20 40 


6626 05 


58382.15 


1833 44 


1032 64 


5551605 







' Revenues and costs maintained at 1978-1980 levels 

2 Timber values appreciate 1 8 percent per year faster than management costs 



93 



Response: In the scoping process a member of the 
public requested that an analysis of the economic 
efficiency of forest management practices be 
made. This person also requested that the genetic 
yield, costs and revenues used in the analysis be 
displayed. Table B-6 of the DEIS summarized 
those data for a hypothetical average acre in the 
Roseburg District. 

Arrayed below are the district's experienced costs 
by treatment, and the derived average cost per 
acre used to calculate the baseline figures listed in 
the table above. Treatment costs per acre were 
based on the district's contracting experience from 
1978-1980. Each practice is applied only to areas 
needing treatment. The average cost per acre 
regenerated equals the cost of the treatment times 
the proportion of acres receiving treatment. 



Roseburg 
District Cost for the 
Cost per Average Acre 
6 



Age of 




Acre 1 


Table B-i 


Stand 


Treatments 


1978-1980 


DEIS 





Burning 


$189.28 


161.07 




Scarification 


63.64 


4.86 




Paper Mulch 


495.72 


13.64 




Herbicide 


63.18 


43.30 




Initial plant 


115.49 


115.49 




Seed and 








Seeding 








Cost 


100.30 


100.30 




Artificial 








Shading 


212.62 


59.33 




Protection 








Against 








Big Game 


269.73 


42.40 




Rodents 


269.73 


13.79 




Livestock 


74.12 


3.77 






Sub Total 


557.95 


1, 2 


Herbicide 


62.08 


6.96 




Protection 


264.96 


12.52 




Replant or 








Interplant 


137.27 


21.14 




Seed and 








Seedling 








Cost 


100.30 


9.92 






Sub Total 


50.54 



Release 



63.79 



16.07 



' Includes district planning, contract preparation and administration, 
overhead and contractual costs 



94 



Response to Written Comments 

Each written comment letter from individuals, 
organizations or agencies was assigned an index 
number in consecutive order as received. 



Letter 

No. Agency, Organization or Individual 

1. Rogue Valley Council of Governments 

2. USDI, Bureau of Mines 

3. 1000 Friends of Oregon 

4. Oregon State Dept. of Forestry 

5. Cheryl Kolander 

6. L.J. Fullerton 

7. Wildlife Management Institute 

8. Riddle Laminators (17 signatures) 

9. Seek, Inc., Realtors 

10. Larry D. Higbee 

11. Umpqua Chapter, Southern Oregon 
Resources Alliance (SORA) 

12. Oregon Wilderness Coalition 

13. Dale S. Sawyer 

14. Rodney F. Greene 

15. Umpqua Valley Audubon Society 

16. Umpqua Valley Audubon Society 

17. Clifford M. Bryden 

18. Gordon Thoreson 

19. L.A. Kostur 

20. Umpqua Dairy Products Co. 

21. Umpqua Savings and Loan 

22. Commercial Title Co. 

23. Bohemia Inc. 

24. Harmony Farm 

25. Western World Realty, Inc. 

26. Thomas A. Lawler 

27. Wayne Peterman 

28. Lorraine Michal 

29. Champion International Corp. 
30 James A. Little 

31. Glide Lumber Products Co. 

32. USDI, National Park Service 

33. Richard Chasm 

34. Douglas National Bank 

35. Roseburg Area Chamber of Commerce 

36. L.L. Burr Logging Co., Inc. 

37. Robert Dahne 

38. Mary Lou Goodin 

39. Les Sanders 

40. Becky Nelson 

41. Barbara Nelson 

42. N. Carlene and W. Rick Wilkinson 

43. Umpqua Community College 

44. Sun Studs, Inc. 

45. Lois J. Gilbert 

46. Stuart Richert 

47. Weyerhaeuser Company, Western 
Oregon Region 

48. William L. Streitz, M.D. 



Letter 




No. 


Agency, Organization or Individual 


49. 


Bob Flynn 


50. 


Ralph Saperstein 


51. 


Joel Rosenberg 


52. 


Lloyd R. Van Doren 


53. 


Ronald V. Widener 


54. 


Dale Bonnell 


55. 


Gene H. Landout 


56. 


Howard W. Johnstone 


57. 


Mark and Roberta Kincaid 


58. 


Roseburg Lumber Co. 


59. 


Mark A. Lowry 


60. 


Lynda Oebel 


61. 


Chuck Kempas 


62. 


The Neil Company Realtors 


63. 


John Rard 


64. 


Mrs. T.L. Suhrstedt 


65. 


James R. Fourtner 


66. 


Mrs. R.J. Parlik 


67. 


Carolee Fourtner 


68. 


Douglas Timber Operators 


69. 


Association of O&C Counties 


70. 


Ken Shrum 


71. 


Western Forest Industries Association 


72. 


Wade Mosby 


73. 


Richard Mitchell 


74. 


USDI, Fish and Wildlife Service 


75. 


City of Sutherlin 


76. 


William E. Markham, State Representative, 




District 46 


77. 


Richard Croucher 


78. 


Harold F. Anderes 


79. 


Floyd G. Sackett 


80. 


Associated Oregon Loggers, Inc. 


81. 


Jozef Reynaerts 


82. 


Corey John Bidwell 


83. 


North West Timber Association 


84. 


William C. West 


85. 


Oregon Dept. of Fish and Wildlife 


86. 


U.S. Environmental Protection Agency 


87. 


Ellis W. Antrim 


88. 


Marilyn J. Smith 


89. 


Duane L. Smith 


90. 


USDA, Forest Service, Pacific 




Northwest Region 


91. 


Industrial Forestry Association 


92. 


Cecil and Phyllis Hubbs 


93. 


Cameron LaFollette 


94. 


USDC, National Oceanic and 




Atmospheric Administration 


95. 


Oregon Executive Dept., Intergovernmental 




Relations Division 




2-1 



United States Department of the Interior 

BUREAU OF MINES 

WISI IRN Hill) OPERA I IONS ( INI t.K 

I \si IGO )RD w h Nil 

sink \si . \s \sllls, I ms , i 

July 22, 1982 



Memorandum 

To: James E. Hart, District Manager, Bureau of Land Management, 

Roseburg, Oregon 

From: Chief, Section of Minerals Involvement 

Subject: Draft Environmental Impact Statement (DEIS) for the 
Roseburg Timber Management Plan 

We found the statement well written except for lack of comments on mineral 
resources. The proposed action is not expected to adversely affect mining or 
mineral resource utilization in the area. However, the disclaimer on page 63, 
that the proposed action will not significantly affect mineral resources, 
should be preceded by at least a brief discussion that describes the existing 
mineral related activities. 

The discussion of socieconomic conditions fails to mention the strategic 
importance of the only operating nickel mine in the United States. This mine, 
the Hanna Nickel Mine located near Riddle, in Douglas County should also be 
described briefly because of its' economic importance to the local community. 

Thank you for the opportunity to review the draft statement. 



95 



Response to comments in Letter 2. 



The purpose of EIS scoping is to focus only on those issues that 
relate to significant effects of the EIS alternatives Analysis, 
including the scoping process, indicated that timber management would 
not significantly impact mining or future mineral resource 
utilization. Therefore, as stated on page 63 of the DEIS, these 
topics are not discussed. 



D. P. Banister 



1000 FRIENDS OF OREGON 



400 DEKUM BUILDING, 519 S W THIRD AVENUE, PORTLAND. OREGON 97204 (503) 223-4396 



Response to comments in Letter 3. 



3-1 



July 19, 1982 



Bureau of Land Management 
Roseburg District Office 
777 N.W. Garden Valley Blvd. 
Roseburg, OR 974 70 

Re : Roseburg Timber Management DEIS 

To Whom It May Concern, 

I am writing to express concern over the omission of 
a discussion of certain recent studies by Dr. Robert R. Curry 
in the subsection entitled "Impacts on Soils" in Chapter 3 
"Environmental Consequences " at pages 64-66 . 

Dr. Curry, on the faculty of the University of Cal- 
ifronia, Santa Cruz, testified before Congress in 1971 that 
"[p] resent evidence suggests forest cutting, by any but the 
most conservative and careful methods appears to completely 
defeat the nutrient cycling and soil nutrient storage capacity, 
as well as increase erosion . Western forests may have less 
than 200 years of productive fertility remaining before per- 
manent. . .eradication of productivity for saw timber production, 
since then Dr. Curry has refined and expanded his hypotheses 
and is chairing a National Academy of Science Study on its 
relevance to agriculture . 

It is distrubing that such a fundamental issue as 
longterm soil productivity should be treated in such a 
summary fashion that Dr. Curry's work is not cited once. Soil 
productivity is one of the fixed limitations which should con- 
trol the decisions concerning use of and investments in, our 
national forests . 




3-1 The literature includes many authors whose work has not been cited in 
the DEIS. Although the literature is not conclusive, recent work has 
shown soil productivity to be affected as indicated on page 66 of the 
DEIS 

This issue was also addressed in the promulgation of guidelines by 
the 92nd Congress. Titled "Clearcutting on Federal Timberlands," 
Report by Subcommittee on Public Lands (commonly referred to as the 
Church Report), this document has been adopted by BLM as indicated on 
page 19 of the DEIS. 



RL/cms 




Forestry Department 

OFFICE OF STATE FORESTER 

260O STATE STREET SALEM. OREGON 97310 PHONE 3782560 



July 28. 1982 



Mr. James E. Hart, District Manaoer 

Roseburg District 

Bureau of Land Management 

777 N" Garden Valley °!vi. 

Roseburg, Oregon 97470 

Dear Mr. Hart: 

The Oregon State Forestry Department has reviewed the Roseburg Timber 
Management Draft Environmental Impact Statement . We are pleased to note 
the consistency of the proposed action with the basic objectives of the 
Forestry Program for Oregon, especially with regard to the production of 
timber. 

While we support the direction of the proposed action I am particularly 
concerned with the need to conserve the existing commercial forest land 
base as an essential element to offset projected timber supply shortages 
in this Timbershed. We would like to offer comments in four general 
areas including; selection of an alternative, consistency with the 
Forestry Program for Oregon, intensive management and the scattered owner- 
ship pattern. 

I hope these comments will be useful and I trust they will be given adeguate 
weight and consideration in the final environmental impact statement. 



H. Mike Miller 
State Forester 
HMM:jp 
cc: Board of Forestry 

Executive Staff 

Congressional Delegation 

Pat Amedeo 

Tom Lane 

William Leavell, BLM State Director 

State Clearinohouse (PNRS #0R 820628-068-4) 



4-1 



Oregon State Forestry Department Review of 

Roseburg District Timber Management 

Draft Environmental Impact Statement 



During our coordination effort, the Forestry Department has raised a number 
of issues at various Input stages In the planning process. Some of these 
concerns have been resolved, however we dre interested in further discussion 
of the following issues In the EIS. 

Selection of an Alternative : 

Generally we support the direction of the preferred alternative since 
it provides a harvest level and proposed management program comparable 
to the "Objective" level identified in the 1980 Timber Supply Assessment 
for the Roseburg Timbershed. In brief, the Assessment points out that 
while BLM is nresenMy harveitino timber at a reasonably attainable level 
in western Oregon, overall harvest levels in most tlmbersheds are ex- 
pected to decline. BLM could help alleviate this potential shortfall by 
increasing its present harvest by an averaae of 7% in western Oregon. 

Consistency with FPFO : 

It is the Board of Forestry's policy to promote a statewide Forestry 
Program for Oregon which meets certain objectives: maintain the existing 
commercial forest land base, maintain or increase the annual allowable 
harvest, utilize a full range of intensive management practices, and main- 
tain community stability. 

Forestry has encouraged the BLM to be consistent where possible, with these 
State objectives. 

A table showing BLM harvest projections from the 1980 Assessment were 
provided your office in a memorandum dated July 19, 1982. We would like 
to incorporate these harvest levels into the consistency table as a bench- 
mark for comparison of community stability. 

The reasonably attainable harvests for the Roseburg District would be: 

1980 1990 2000 2010 2020 

MMCF 40.3 39.5 39.2 38.8 38.7 



As you note, the harvests projected are not constrained by an artificial 
limitation such as non-declining even flow, but are in accord with the prin- 
ciple of sustained yield. 

Additionally, we feel some limited opportunities exist to increase this 
harvest level in some timbersheds from a "surplus inventory" or as a 
"cooperative harvest" target. This increased harvest is intended to make 
up for the "fall down" expected in some timbersheds to ease community 
transition to a sustained harvest from all owners. 



Intensive Management : 

In order to rank alternatives 
Objective to maximize growth 
4 — 2 |P ract ' ces - tne EIS should dis 
I of practices that are accompl 
Information in the DEIS does 
sive management practices in 
of Proposed Action and Altern 



4-3 



4-4 



types and levels of treatment 
the process of computer model 
because most of the land base 
in needed treatments currentl 
these projections make meanin 



accordino to thei 
through increased 
play the differenc 
ished and that pro 
not provide a basi 
a comparative mann 
atives by Treatmen 



r consistency with the FPFO 
intensive management 
e between the current level 
posed for each alternative, 
s by which to measure inten- 

Table 1-2 titled Comparison 
First Decade displays the 



as a comparison 
ing acres tend to 
over time is cons 
y and combinations 
gful comparisons d 



with the proposed action. In 
be treated by percentages and 
idered for treatment, backlog 
of treatments occuring during 
ifficult. 



In the FPFO consistency table our benchmark is to "implement a full range 
of intensive timber management practices for optimization of timber pro- 
duction". Using the information in your table this could be a comparative 
target number such as a percent of the CFL land base receiving basic inten- 
sive management treatments during the first decade. 

To better provide a benchmark consistency target, OOF suggests that you 
display acres for each of the basic intensive forestry practices implemented 
as a percent of the CFL base projected for each decade. 

We estimate that 35% of the CFL base currently receives some intensive 
management treatment. (Plant, Rehb. Release, PCT, CT and fertilization). 
The Preferred Alternative would result in about 65% treated. Alt. 1, 2 
and 3 are greater than 65% and Alt. 6, 7, and 8 are less than Alternative 5 
and would be inconsistant with FPFO in our opinion. 

Scattered Ownership Pattern : 

One issue not addressed in the DEIS is the checkerboard pattern of ownership 
characteristic of & C lands. The operational problems due to this 
pattern affect the management programs for both commercial timber production 
and amenity values. It is uncertain how the objectives of programs for 
visual resource and wildlife habitat can be implemented with uniformity and 
measured objectively. This problem needs to je disc-^s?-i in cone details 
in the Environmental Impact Statement. 



Response to comments in Letter 4 

4-1 FPFO forest harvest levels for the 1980 decade have been incorporated 
by text revision (see FEIS Chapter 1 State and Local Governments 
under Interrelationships section). 

In addition, FPFO harvest levels for decades 1980 - 2070 are shown 
below Volumes in MM bd. ft. were converted frcm 32-foot to 16-foot 
log rule for direct comparison throughout the EIS. 



BLM Harvest Projections - 1980 TSA 
(MMCF & MMBF/Yr jl 
Decade 
BLM Unit 1980 1990 2000 2010 2020 2030 2040 2050 2060 2070 
Roseburg 

MMCF 40.3 39 5 39.2 38-8 38.7 38. 2 37.7 37.2 37.0 36 7 
MMBF 245.4 235.4 247.1 237.7 208.3 160.8 141.6 161.3 168.7 167.2 



i Harvest in each decade sustainable for seven additional decades in cubic 
feet (incremental even-flow). Harvest in board feet is based on 16-foot logs, 
Scribner Log Rule. Converted by D. Preston (OSO) 8/4/82 frcm OSDF original 
submission 



4-2 The following tables sh Tactices 

i . 

i Ac. Planned Ac. Planned 

; i ice (1 972-1981)* A lternative 4** Alternative 9* 

31,866 103,010 









102,197 



68,027 



97 



The acres toe each intensive management practice planned for the 
first decade are shown in DEIS, Table 1-2. On the commercial forest 
land base 92.5 percent of the intensive management acres harvested in 
the first decade will receive spacing control and fertilization, 
planting with genetically improved stock will also occur on 
approximately 30 percent of the acres harvested in the first decade. 
This would increase to approximately 92.5 percent by the fourth 
decade. 



2,289 



31,076 



40,284 



9,365 

Ac. A i Ac. Planned 

(1972-1981)* Alternative 4* 






Ac. Planned 
Alternative 9* 



14 , J45 40,755 40,449 

Lnning 1 , 119 3,479 1,383 

56,029 55,646 

15,200 15,200 

146 

24,964 3,347 3,328 

■ i wth Man3jejnent Camiittee Report 

:• L-2 



Other harvested acres would not be subject to intensive timber 
management practices that are yield enhancing. 

By the fifth decade all intensive management practices would be 
scheduled at maximum levels. The percentage of commercial forest land 
scheduled for each intensive management practice is shown below: 

Percent Commercial Forest Land Base* 
Scheduled for Intensive Management 
(Fifth Decade and Beyond) 
EIS Alternative 



2 3 4 5 6 7 

85 79 79 23 53 37 



8 9 
78 



Intensive Mgt. 

Practice 

Spacing Control 

( Pre . Carml . & 

Comml . Thinning) 

Fertilization 

Tree Improvement 

•Percent scheduled by practice (Commercial Forest Land Base 391,070 



M 


85 


79 


79 





53 





78 


9] 


85 


79 


79 


73 


53 


68 


78 



•) on page 82 of the DFIS. BUI recognizes the "ability to 
- quality is often 1 united by 

■■ 

ler the various alternatives also 
i ownership. 

It is not the Lnten! ontrol or influence private land 

management decision-, ■ r red or any of the other 

alternati k+i <.>>ntf)i ■ ,r influence. 



5-1 



D! iJT E.I.S. 



1. 



rile 



5-2 1 



- ■ ■ . ons, but rbther, 

-T.snt alternatives must be discussed. In .specific, the alternative 

--vest: var >f sevectlve - shelter- 

c leer cuttin . of land, 

■ .re -rees. 

" la -• lysis. Specif] cally: 

full-sus ..-.tes. 

2. 

- er.t error in that :r.e NoM 

he acreage re. 
: -s to oe reJuced I r« :ed siie, ar.r 

size p.- ! 

rt of tr.e i. . . 



5 — 3 | Tnere ., assos sed ne 

- 
Lvity, recreation, etc., must .lave cleai 
■ ■ ■ is pursuant 

11 r - J ...suroa ore , iC t 5 are too sevore 

to alio* justil ferred Alternative, E iven all applicable conservation 



the case no i-res are u bo delineated and odooted, a j-usti:. 

Ls must be nude. .. CFS. a worst case scenario sust be 

developed and ox i isbj : or public scrutiny. 



£^yV^^^ 



Cneryl Kolander 



98 



Response to comments in Letter S. 

5-1 The public scoping process that preceded development of the DEIS 

identified the issues addressed in the EIS alternatives as the most 
important and relevant for analysis. The EIS does address several 
different timber management options, including: no herbicides, no 
fertilizer and smaller minimum harvest size. Specific management 
practices, including various harvest methods, are described in the 
BLM Timber Management Final EIS 1975, which is incorporated by 
reference. Alternative harvest methods are considered on a site by 
site basis, utilizing the appropriate method to mitigate a potential 
impact. 



In the EIS, Chapter 1 references the BI* Tinb i it Pinal EIS 

1975, which includes a detailed listing of mitigating measures. 
Chapter 1 also describes project design t ■ .i , ■ -• 
mitigating measures feasible to implement without changing an 
alternative or impacting the allowable cut associated with a 
particular alternative. Additional means to mitigate adverse 
environmental impacts are discussed in Chapter 3. 



The North Myrtle proposed RNA acreage is correct as shown in the DEIS 
(Table 2-14). The Proposed RNA was reduced to approximately 240 acres 
in the Original Proposed Action (Alt. 4). This protects an area 
sufficient to meet RNA cell needs and sensitive plant habitat, while 
leaving the remainder open to other management activities. There are 
no minimums established for RNA size; some RNAs are 80 acres or less. 
Note: the entire 480-acre parcel is part of a serai stage block in 
the new Preferred Alternative (Alt. 9). 




DANItl A POOIE 

i K |AHN 

L- L. WILLIAMS! in 



Wildlife Management Institute 

70S Wire Building. lOOOVefmonl Ave . N W . Wash. ngton, O C 2000$ • 202 



August 12, 1982 



Mr. James E. Hart 

District Manager 

Roseburg District Office 

Bureau of Land Management 

777 NW Garden Valley Boulevard 

Roseburg, Oregon 97470 

Dear Mr. Hart : 

The Wildlife Management Institute submits its comments on ROSEBURG 
TIMBER MANAGEMENT ENVIRONMENTAL IMPACT STATEMENT, Oregon. We usually would say 
we are pleased to submit comments, but this time it is a sad occasion. 

Your plan is good, probably about the best that could be expected 
from the lands in the Roseburg District. It is not quite as good for wildlife 
as the Coos-Curry plan. However, both have now gone down the tube— negating the 
many years work to bring 06.C lands under some kind of multiple use. 

We are referring to the July 15 memo from the Director. The third 
paragraph throws out Sikes Act and other agreements with the state and other 
agencies on spotted owls as "interim." It says in part "Habitat through land 
use allocation in these instances on OSC lands will be provided only to the 
extent it 



7-1 



es from noncommercial timber lands." 



This is done at a time when, in the real world, some purchased timber 
has stood uncut for over 3 years, sales are down and some timber offerings are 
not being sold. 

Several years ago a humorous sheet was circulated in Oregon giving 
a recipe for Roasted Spotted Owl. That may no longer be a joke since July 15. 

We see no reason to make our usual detailed analysis of the plan, as 
it will be completely changed by the time the final EIS is prepared. 

We do wish to call your attention to one important fact, however. 
The 423,896 BLM-adminlstered acres contain tracts of Public Domain. This land 
is subject to FLPMA. We insist it be managed for multiple uses--and in this 
case we define those uses as old growth since somewhere in the OSC mosaic there 
should be a tree older than rotation age. 



Mr. James E. Hart 



August 12, 1982 



Perhaps the great need is to repeal the O&C Act, removing the boon- 
doggle Oregon counties receive of 75 percent of the long time average $300,000,000 
a year from timber sales. This diversion of federal funds still occurs at a time 
when our government proposes selling public lands to retire the national debt. 
The government does not seem worried about subsidies to Western Oregon counties 
or to the livestock graziers of the West. 

We view this action as short sighted and a detriment to long-term 
management of OSC lands. This reversal to single use management will draw 
attention to the basic inequities of the OiC Act and hopefully will result in 
its amendment or repeal. 

These remarks have been coordinated with William B. Morse, the Institute' 
Western Representative. 



Sincerely, . — .. 



Daniel A. Poole 
President 



DfOIC<\TEDTOWIMUff 



11 



99 



Response to oanments in Letter 7. 

7-1 The Bureau agrees that management of Public Domain (PD) lands is 

governed by FLPMA. The Preferred Alternative and most other 
alternatives would provide for management of the Public Domain (PD) 
lands under multiple use concepts. Due to the small amount of these 
lands, i klm analysis showed they cannot by themselves satisfy old 
■ objectives for wildlife habitat. The PD lands in 
m Oregon are combined with O&C lands for allowable cut 
calculation purposes. 



August 12, 1982 



Mr. James Hart 

District Manager 

Roseburg District BLM 

777 N.W. Garden Valley Blvd. 

Roseburg OR 97470 

Dear Jim: 

The Umpqua Chapter of the Southern Oregon Resource- 
to continue its participation in the planning and management &■ I 
of the District by submitting our comments on draft EIS 
Timber Management Plan. 

The goal of our organization is to seek out a balance in resource issues 

that provides economic stability for Douglas County, while pro-. 

the protection of the environment so key to ma 

life we all enjoy. Our membership and our Board of Directors represents 

a cross-section of the community from those with strong resource utilization 

interests, to those with strong concern for re - environmental 

concerns. Contrary to our friends in either the La 

groups or the timber industry, we are not single-use or objective oriented. 

Furthermore, unlike some local advocate groups, we are aware of the 

differences in purpose between BLM and Forest Service management. Indeed, 

we believe our organization represents the "community" that the 06C act 

referred to when it discussed providing for economic stability, watershed 

management, and recreational opportunity. 

In reviewing the activities leading up to the draft EIS 
board meeting, one factor became quite clear. You and youi 
done an outstanding job of listening to the public concerns and 
demonstrated a sincere concern for the needs and desires of the majority 
of the local population. The dedication and professionalism demonstrated 
by you and your staff is most appreciated by our organization. 

In reviewing the EIS and recent planning criteria established by the 
Bureau, it would appear that our input is needed in two areas: 

I. Contrary to other planning efforts, the proposed action can be 
changed in the final EIS to reflect Bureau laws and policy leading to the 
actual decision. Input should therefore deal with what our organization 
believes the proposed action should be in the final EIS. 



11-1 



11-2 



II. The adequacy of the EIS in terms of properly displaying the 
environmental and human effects of various alternatives. 

During the Boards review of the EIS, it became clear that we, as lay 
members of the public, cannot evaluate such technical items as harvest 

nptions, road desiqn, environmental mitigation or fish and wildlife 
niques. Rather, we must examine such documents from the 
vantage point of outputs and how well they meet our criteria for 

rtunity, water quality, wildlife populations, complj 
with : )'•--, and economic stability in terms of jobs and public 



We had ■ the timber industry would be pushing for a full, 

inagement option such as described by Alternative 
what surprised when the industry asked that SORA 
considei joining wi istry in supporting Alternative 2. We 

ort because the EIS does 
he probata Lity of 
alternative. Uscussion and review, the 

i SORA was unanomously adopted: 

i:R OF SORA URGES THAT THE BLM ADOPT ALTERNATIVE 2 
AS THE PROPOSED ACTION IN THE I MENTATION 

AS TH DED THE FINAL EIS DEMONSTRATES THAT SORA'S 

OBJECTIVES IN THE AREA. TY, RECREATIONAL 

ROWTH AND ECON " CNDEED MET BY 

" 



11 — 3 I T he public should be given the opportunity to comment on specific areas. 

We are concerned that some areas, such as Slide Over, may be more political 
in nature than based on demonstrated need, or the area's attributes, when 
compared to other potential areas in the state. 

RIPARIAN AREAS AND WATER OJJALITY -It would appear that with the allocation 
of over 18,000 acres of streamside units, that water and fisheries' values 

I are well provided for in Alternative 2. In addition, the EIS should analyze 
how these areas can best be managed to provide for old growth and other 
wildlife needs. 

WILDLIFE -We recognize that as the composition of the forest changes from 
predominately old growth to a managed forest, there will be changes in the 
wildlife populations. However, there will still be an abundant population 
of wildlife for the public to enjoy. This concept has not been adequately 
discussed or described in the EIS. Considering the O&C 

lands, we do not think it necessary that every species now 
land must always be found on BLM lands so loi Sone- 

where in the region. With the Riparian zone . i LI not 

be managed intensivly for timber, this is not a serious concern. 



11-5| 



Ilt was pointed out in an earlier planning document 
decades before any wildlife population will be sigr 
think this concept should be carried forward into t 



.11 be several 
icantly impacted. We 
final EIS. 



Following are in areas of concern to SORA along 

In the analysis in the final EIS. 



ith 



NORTH UMPQUA RIVER -Qur organization is particularly concerned that your 
management of the ri Lc beauty of the area, as 

reased recreational pressure on the 
area. Because it i: ltive area, it deserves specific discussion 

for increased day and overnight use 
Increased river crossings for foot traffic, and increased 
'he once proposed Bob Butte road. We would 
' mprovement oi 

RECREAT T naximum recreational 

opporti ment. This should include 

:i iged forest, 
tyout, as well as 

■ 

I \REAS OF CRITICAL ENVIRONMENTAL CONCERN AND RESEARCH-NATURAL AREAS - I t 
appears that the ACEC's desicions will be made as part of this planning 
, yet the EIS fails to give specific descriptions of the areas that 
ild be included, why they are included, or how they would be managed. 



11-7 



11-8 



11-9| 



OLD GROWTH AND THE SPOTTED OWL -SORA appreciates the values of old growth 
and the apparent uniqueness of the spotted owl. It has also become abundantly 
clear in recent months that a great deal of study and research is needed on 
the subject, while the EIS indicates the spotted owl will be gone from the 
district in a hundred years, the arguments are not at all convincing. We 
think that opportunities to manage for the owl without the large habitat 
allocation must be examined. Clearly on this district time is not a 
critical issue since it will be so long before the major portion of the 
old growth is scheduled for harvest. 

Your EIS should show the public how many of the owls you can protect for 
the first ten years as well as for future decades under each alternative 
by carefully scheduling your timber sales. It would appear that we have 
several decades in which to determine a proper old growth policy on the 
district. In the meantime, the Forest Service will develop its local 
plans and the researchers can provide the answers to the many questions. 
The EIS should deal with total old growth on the district, not just the 
commercial forest lands. 

TIMBER SUPPLY AND LOCAL ECONOMIC STABILITY -It is clear at this point that 
some significant increases in the even flow sustained yield are possible 
from the Roseburg BLM. For this we are thankful, as our industry will need 
the timber and our community will need the jobs once the current national 
economic climate improves. It is our understanding from the EIS that 
actual harvest levels will fluctuate depending upon the funding levels 
approved by Congress and the price of timber. It also appears that in order 



100 



to reach the level of harvest 'ou will need big increases 

in funding. We find this very unlikely in the next few years. While we 
support youi ry, we are concerned that the 

I prop' ii Therefore, we would ask that the 

i IS display the harvest level for each Levels 

of funding (current, 10* higher or lower, 15* higher or lower, etc.). 



11-11 



As you know, a timber shortage is predicted for this region in the next 
thirty years or so. While you discuss the Forestry Plan for Oregon, 
feel a more detailed discussion of BLM opportunities to help protect 
shortage should be discussed in your final EIS. 

CONCLUSION- Based on the information available, SORA is pleased to support 
Alternative 2. It will provide for affordable increases in harvest which 
will provide a favorable climate for increased employment and economic 
recovery while protecting the environment and preserving the quality of 
m Douglas County. Options for future old growth allocations will 
remain in place until future plans are developed and better knowledge 
ll; available upon which to make rational decisions. We urge that you use 
Alternative 2 as the proposed action in the final EIS so that we may more 
fully analyze its effects in the decision process. 

On behalf of the Board of Directors, 



Georgia H. Stiles 
President 



cc Bill Leavell, State Director 
Bob Bur ford. Director BLM 
SORA Board of Directors 



Response to comments in L/?tt<-r 11. 

11-1 The North Umpqua River is discussed on pages 48, S3, and 84 ol 
DEIS. Specific development opportunities will hr- addrr-:, 
subsequent detailed management plans and environmental assessments. 

11-2 Recreation facilities and opportunities are described on pages 47-50, 
80-85 and 126 of the DEIS. Additional details are available at the 
Roseburg District Office. 

11-3 USDI, BLM 1980a {see References Cited) contains general policy and 
guidelines for ACECs. Further information, including the proposed 
Management Framework Plan (MFP), an ACEC identification summary and 
ACEC plan element, is available in the Roseburg District Office. The 
identification summary documents the criteria evaluation, staff 
analysis and public participation for nominated and proposed ACECs. 
The ACEC plan element provides a specific description, management 
objectives and special management requirements for all proposed 
ACECs. Details were published in Roseburg District Planning 
Newsletters 9, 10, 11 and in Brochures on Draft and Preferred Land 
Use Alternatives. The public was given opportunity to nominate areas 
and comment on potential areas through the response to land use 
alternatives from the above listed brochures. Following designation, 
activity plans are prepared to translate management requirements into 
on-the-ground implementation actions. 



11-4 All EIS alternatives, except Alternative 1, provide an allocation for 
riparian habitat. Although this habitat meets many wildlife needs, 
Lang (1980) states that narrow riparian strips containing old growth 
trees do not constitute old growth ecosystems because of the lack of 
an old growth microclimate. As a result, opportunities to provide the 
needs of old growth dependent wildlife species through riparian 
habitats are quite limited. 



11-9 The DEIS analysis, including Table 3-9 and Appendices E and F, 

addresses all old growth within and outside the commercial forest 
land base. Withdrawn areas and non-intensive commercial forest land 
have been used to satisfy a variety of resource uses, including eagle 
habitat, riparian areas, owl habitat, scenic values, etc. 

11-10 See response to common issue 2. 



11-5 Refer to DEIS, Chapter 3, Impacts on Animals section, pages 72-77. 
Also, see response to common issue 1. 



11-11 See response to comment 4-1. 



11-6 See response to common issue 1. 

11-7 The EIS analysis focused on short- and long-term impacts to the 
spotted owl based upon current information. Refer to Chapter 3, 
Impacts on Animals, Threatened and Endangered Animals and Conclusions 
' sections. Also, see response to comment 83-6. 



For the first ten years, under original Task Force guidelines, at 
least 25 pairs of owls would be expected to remain under the 
Preferred Alternative (Alt. 9) as a result of land use allocations 
and harvest scheduling. To assess the effect of timber harvest 
actions on spotted owl populations at the end of each decade for each 
alternative, it would be necessary to have detailed long-term timber 
sale plans. Since this has not been done, the issue cannot be 
adequately assessed. Refer to Chapter 1, Table 1-5 and Chapter 3, 
Impacts on Animals, Conclusions section. 




12 



regon Wilderness Coalition 



Main Office 271 Wesl 12th Avenue Eugene Oregon 97401 [503 J44-0675 
Mi tro i »ffice IX-kum Building, 519 SW ,»rd Avenue, Suite 706, Portland 

Oregon 97204 (5031 224-0201 
Eastern Oregon Field Office Box 9 Prairii Cit) Oregon 97869 S03 820-3714 



101 



Response to comments in Letter 12 . 



12-1 Under Council on Environmental Quality regulations (40 CFR 

1502.14(a)), an EIS must consider a range of reasonable alternatives. 
Many reasonable alternatives may be inconsistent with current agency 
policy. The possibility always exists that the EIS analysis can lead 
to revision or policy. 



12-1 




We are not so poor we musx destroy oui wilderness, nor so rich we can afford to — newton urury 



15 




15-1 



15-2 



Umpqua Valley Audubon Society 

P.O. Box 381, Roseburg, OR 97470 

August 18, 1982 



lr. James Hart, District Manager 
Bureau of Land Management 
777 N.W, harden Valley Blvd. 
Roseburg, Oregon 97470 



Dear Mi 



Enclosed are our omaniza 
Manaaement Environmental 



tion s comment 
Impact Stateme 



nt the comment 
ard of directo 
nto the draft 

was done deta 
d result from 
o thank some < 
nswering quest 
Dick Norland . 

to meet with 



s on the R oseburg Timber 
nt issued in June of 19 82 . 
iade in the 15-page 
We were impressed 
statement and felt that 
iling many of the environ- 
the various alternatives. 
f your staff for the time 
ions that I had about the 
nd Dave Palmer all took 
me and I certainly aporeci- 



This letter will supoleme 
document signed by our bo 
with the work that went i 
a relatively thorough job 
mental impacts which woul 
I would especially like 
that they spent with me 
statement. Bob Albei 

from their schedules 
ated i t . 

Soc io-economic Impacts 

The analysis of the economic impacts of the various alternatives is 

This part of the impact statement is critical because 
ill o^ the dearadinq of the environment that occurs in alternatives 
1 throuqh 5 is beina done basically in the name of economics and 
community stability. An adequate decision cannot be made unless the 
economic analysis is adequate. 

1) The statement determines the existing situation to be 187.5 
MM bd. Ft. This average is obtained by considering the years 1976 
through 1980. The analysis should include the last 10 years rather 
than t Lve. In addition it should include the figures for 

■ear 1981. 

2) The averaqe 12-month harvest should be determined using a 
number of different years. If the existing situation were based on 
the averaqe harvest for the last three years, i.e. 1979, 1980 and 
1981, isults would occur. For example, the 

h harvest for 1979, 1980 and 1981 is 159 MM bd. Ft. 
this figure as the existing situation, all of the alternatives 



15-2 



15-3 



15-4 



15-5 



15-6 



15-7 



Mr. James Hart 
August 18, 1982 
Page 2 

except for alternative 8 would result in an increase in timber 
harvesting and alternative 6 would increas e the number of jobs 
in the local economy by approximately 400. 

3) On cage 87 it is stated that the economic projections 
assume that under each alternative the timber is promptly harvested 
and processed. The statement should include information on the 
current situation. For example, if there is a backlog of timber 
that has been sold but not harvested, that information should be 
available to the public and the decision maker. 

4) The statement should analyze whether the timber market 
can support the increased harvesting that is projected by some of 
the alternatives. It should analyze the impact that a rapid 
conversion of public old growth timber will have on the timber 
market. It should attempt to analyze whether a reserve of old 
growth timber will have a stabilizing influence on timber prices 
and whether a rapid conversion of old growth timber would result 
in a substantial increase in the value of privately owned timber. 

5} Because one of the main objectives of the O & C lands is 
to stabilize local economies, the statement should analyze the 
apparent trend towards diversification that is occur ing in Douglas 
County. It apoears to be the goal of most Dolicy makers in 
Douglas County to diversify the economy so that the swings in the 
housing market caused by national recessions will not result in 
such dramatic increases in unemployment in Douglas County . I f 
some of the alternatives would result in the forest industry in- 
creasing its Drecentage of the market place in Douglas County, a 
federal bureau could actually be working against local economical 
stability. 

Water Quality 

1) There aopears to be no statement of the actual State and 
Federal quality standards which must be met in the sustained yield 
unit. This information should be included in the statement. 

2) On page 68 it is concluded that substantial increases in 
nutrient concentrations following forest fertilizations are not 
expected. No sources are given for that conclusion. It certainly 
seems that with the amount of research that has been done in 
agricultural fertilization, there must be some research available 
to indicate whether stream concentrations will increase or stay 
the same following fertilization. 



Soils 



15-8 



1) We don't understand why the withdrawals for fragile sites 
is so much smaller than the inventoried fragile soils. Table C-2 



15-8 



15-9 



15-10 



102 

Mr. James Hart 
August 18, 1982 

| on page 125 would withdraw approxi- 
mately 2600 acres for fragile sites. Table 2-14 on page 34 seems 

Mcate that there are approximately 9,000 acres of fr 
soils. 

2) The analysis of the impact of the loss of soil due to 
intensive timber management is inadequate. The statement should 

irnount of top soil that is being lost from the 
forest under each alternative, the amount of top soil that would 
be added to the forest under each alternative and it should project 
whether those top soil losses can go on indefinitely without affect- 
ing the long-term productivity of the sustained yield unit. 

Vegetation 

1) The statement should indicate the impact that the various 
alternatives will have on the present species composition of the 
sustained yield unit. I nresume that in many places in the forest 
mixed stands will be reDlaced by single species and the states- 

I should analyze whether this will vary under different alternatives. 

2) If the change in species composition results in conversion 
of a mixed forest to a monoculture, the statement should analyze 
the environmental impacts of that change. 

M iscellaneous 

1) Some of the Roseburg district lands are public domain lands 
which apparently should be managed under The Federal Land Policy 
and Management Act of 1976. These lands should be clearly identified 
in the statement and the alternatives should assess the impact that 
different legal restraints will have on that land. 

12) It appears that some of the alternatives may violate State 
and Federal water quality standards. If they do, we believe it is 
inappropriate for these alternatives to be considered because they 
are not alternatives that could be implemented. 

13) The statement should indicate the amount of merchantable 
timber that is being added to the sustained yield unit annually at 
the present time. 

4) The statement should indicate what portion of the projected 
harvest under the preferred alternative is due to projections for 
15-14 genetically improved trees, what portion is due to precommercial 
thinning and commercial thinning, and what portion is due to 
fertilization. 



15-11 



15-15 



Mr. James Hart 
August 18, 1982 
Page 4 

I to assess the environmental impacts of their activities on ' 
and wet lands. ,t able to 

concerning the identification of those lands or any asses- 
I of the impact of the alternatives on those lands. 

At this time we do not expect to be submitting any oral stu' 
at the public meeting. 

Sincerely, 






James A. Arneson 

Conservation Committee Chairman 



15-151 



5) Executive Order 11990 and 11880 directs Federal agencies 



Response to ccmnients in Letter 15. 

15-1 The average 12-month sales frcm the Roseburg District frcm 1972 
15-2 through 1981 was 200.2 MM bd. ft. The average 12-month harvest from 
the Roseburg District frcm 1972 through 1981 was 194.9 MM bd. ft. 
Fluctuations of over 25 percent above or below the allowable cut are 
not uncanmon in tracing the annual harvest through the past decade. 

15-3 Timber sold but unharvested in the Roseburg District, as of March 31, 
1983, was 616.9 MM bd. ft. 



total employment provided by the wood products sector by less than 1 
percent For example Table 2-17 reports lumber and wood products 
employment in Douglas County (1977-1980 avg.) of 8.500 and total 
employment of 35,000 Under the no action baseline (Table 3-18), 
Alternative 1 could add 537 jobs in the timber industry with total 
employment increasing by 1,135. During 1977 through 1980 timber 
industry jobs represented 24.3 percent of total employment in Douglas 
County. Under Alternative 1 timber industry jobs would represent 
25.0 percent of total employment in the county. 



15-4 A number of studies which include estimates of the price-quantity 
relationship for lumber and wood products at the national level or 
the derived price-quantity relationship for stumpage from public 
ownerships in the Pacific Northwest are available (Haynes 1977; Adams 
et al. 1977; Adams 1977; Haynes and Adams 1979; Youngday and Fight 
1979; Adams and Haynes 1980; and Haynes et al . 1981). All of these 
studies suggest that changes in supply of timber of the magnitude of 
the alternatives in the DEIS will have no effect on the market 
clearing prices of stumpage or manufactured wood products. 

15-5 Pages 54-55 and Tables 2-17 and 2-18 of the DEIS discuss and display 
recent trends in economic diversification within Douglas County. 
Because timber industry jobs support jobs in other sectors (service, 
retail trade, non-wood manufacturing, etc.), an increase in the 
number of timber dependent jobs would increase the percentage of 



15-6 The State of Oregon has determined that the requirements of the 

Forest Practices Act meet the objectives of State and Federal water 
quality standards. (Refer to ORS 340; copies are available at Oregon 
Dept. of Environmental Quality and BLM offices.) 

15-7 The text has been revised in the FEIS, Chapter 3, Impacts on Water 
Resources, Water Quality section. 

15-8 The withdrawals for fragile sites are part of the TPCC inventory and 
do not coincide with the soil inventory which included fragile soil 
areas (see DEIS, Appendix C, page 123). 

15-9 There is no known research which quantifies loss of forest productiv- 
ity resulting frcm incremental losses of topsoil. 



16 



15-10 Ihe vegetative composition which currently exists in the SYUs is 

described in Chapter 2, Vegetation section. On page 70 of the DEIS, 
it has been noted that vegetation oanposition in the SYUs would 
change according to the level of harvest under each alternative (see 
Table 3-8 and Appendices E and F). Species composition is not 
expected to change, as indicated on page 71 of the DEIS. 

15-11 The issue of separate management was not identified in scoping. 
Therefore, it was not analyzed in the EIS. Also, see response to 
comment 7-1. 

15-12 See response to comment 15-6. 

15-13 The average annual growth presently being added to the intensive base 
for Alternative 9 is 5,165 MCF or 31.1 MM bd. ft. and to the 
intensive and constrained base for Alternative 4 is 5,424 MCF or 32.7 
MM bd. ft. 

15-14 See response to common issue 3. 

15-15 Impacts are expected to be insignificant to wetlands and aquatic 

vegetation for all alternatives except Alternative 1. Refer to DEIS, 
Chapter 3, Impacts on Vegetation, page 69 and to Appendix C, Table 
C-4. 




103 



Umpqua Valley Audubon Society 

P.O. Box 381. Roseburg, OR 97470 



August 18, 1982 

Mr. James Hart, District Manager 
bureau of Land Management 
777 N.W. Garden Valley Blvd. 
Hoseburg, Oregon 97^70 

Dear Mr. Hart, 

The following Is our comment on the June 1982 Lraft Hoseburg 
limber Management Environmental Impact statement. 

The limber Management ols Is Inadequate In giving a balanced 
range of alternatives. Alternatives 1 through 7 proposes to harvest 
between 289 to 176 MMBF per year vs. Alternative B'r Alter- 

natives 1 thru 5 are totally unacceptable from an ecological stan-1 
point to maintain forest diversity. While the prescriptions proposed 
In Alternatives 6 and 7 are not quite as far out of line, wildlife 
and watersheds would only fair slightly better. Our claim Is evi- 
denced from statements in the Dr.13 such as: 

(a) Cavity nesters are predicted to "fall below self-sustaining 
levels" In all but alternatives 6, 7 and 8 and "snag dependent wild- 
life would be greatly reduced In the long term"; 

(b) "Planned timber harvest would so alter cover composition that 
elk populations are expected to decline over time in all alternatives 
except 8." And, "there are no long term provisions for retain! 
mature or old growth forest beyond the fourth decade for survival 
cover In this Important area and this absence could cause population 
declines to proceed faster If severe weather occure 

(c) Alternative 6, and not the preferred alternative, Is the only 
option outside of Alternative 8, that would provide habitat for 25 

or more pairs of spotted owls as recommended by the Oregon endangered" 
Species lask Force under the previous 300 acre prescription. And 
only Alternative 8 would provide a genetically viable pooulatlon 
under the more recently suggested 1000 acre prescrlotlon. 

We feel that Alternative 7. the tfo Herbicide, .io fertilizer Alter- 
native, serves to further accentuate BLK's bias that forestry with- 
out herbicides doesn't work, rather than trying to look for methods 
that would generate some additional employment and would provide us 
with a healthy, poison free environment. 



-3- 



16-1 



16-2 



The Ho Herbicide Alternative does not sufficiently address the 
specific assumptions that allows the BLM to take allowable cut 
credit for the use of herbicides, Manual release methods are 
not fully discussed for which allowable cut credit should also 
be received. 

We feel strongly that Alternatives 1 through 7 provide a skewed 
range of alternatives, shifted heavily to the side of maximum 
commodity production. Yet BLM seemingly expects Alternative 8 
to provide a balanced "extreme" to Alternative 1. Alternative 
1 proposes to harvest 289 MMBF per year. The September 1981 Pre- 
ferred Land Use Alternative document maintains that the district 
only has the potential to produce 2?6 MMBF per year. Similarly 
the DEIS preferred alternative's annual cut of 2^9 KKBF has been 
Increased from September 1981 preferred alternative's recommended 
harvest of 232 MKBF. Are these both suppose to be the same pre- 
ferred alternative? Again, the cut has been skewed to one direction 
with both Alternatives 1 and 2 proposing harvest in excess of the 
prescoplng meeting's maximum timber harvest, Alternative A, which 
proposed 266 KKBF. While the preferred alternative was Increased 
by i4 MMBF and the maximum timber harvest alternative Increased 
by 23 MMBF, Alternative 7 Is only 3 MMBF below the former Alter- 
native C, and Alternative 8 Is only 5 MMBF below what was formerly 
called D. 

We realize that the various alternatives are for purposes of dis- 
cussion and the number of assorted "timber first" proposals doesn't 
necessarily insure that Alternative 8 will not be fairly evaulated. 
However, if a "travel agent" were to open his briefcase and present 
you with seven enticing vacation packages, all In seven states 
east of the Mississippi River, but also happened to have a trip to 
Colorado — although you may leaf through all the pages of the travel 
brochures, no one really expects that the odds are you are going to 
choose Colorado. If however, the travel agent wished to be sure 
that the western part of the country was equally well represented 
in your potential travel plans, It would behoove him to then also 
have a few brochures from Utah, Montana or Wyoming. 

Similarly, we would like to see a few alternatives In your draft 
EIS package other than really only one that's on our side of the 
river. If, for the analogy. Alternative 8 Is to the "west" and 
Alternatives 1.2,3 etc. are to the "east", you have to admit that 
If Alternatives 6 and 7 are "west" at all, then they're still drip- 
ping on the shore where they Just barely got across the rlveri 

Furthermore, Alternative 8 isn't nearly as far "west" as Alternatives 
1.2, 3, 4, and 5 are "east". If you are going to have 5 alternatives 
all In excess of 200 MMBF, then you can consider a few other alter- 
natives less than 100 MMBF. If you wish to have an alternative, 
such as number 1, which by your own admission Is 13 MMBF above your 
potential to produce, then an analysis of the ecological Impacts on 



16-3 



16-4 



16-5 



elk and cavity nesters by only harvesting 50 MiBF, 25 tmaT, or 
KKBF should also be considered. Alternative e would basically 
only allow one population of elk (In the Tyee area) to hold Its own, 
according to the draft ilS. Let's consider an alternative that 
would maximize elk, spotted owls, bald eagles, cavity nesters and 
anadramous fish In all areas of the forest. Only this type of 
alternative would properly balance Alternatives 1 thru 5- In other 
words Its O.K. If your travel agent wants to offer dream trips to 
Bangor, Maine, but let's also have a trip to San Diego, California. 
Alternative 8 doesn't get past Denver, Colorado. 

Ihe "new" preferred alternative Increases timber harvesting by <*8 
MMBF over the current annual allowable cut level, lo harvest this 
timber, four Intensive management practices are employed — spacing 
control In young stands, commercial thinning, fertilization, and 
planting of genetically Improved trees. To Insure that future 
timber management policies and practices do In fact "contribute 
to the economic stability of local communities" as set forth In the 
O&C Act, we ask that the F£IS fully analyze, and present documented 
evidence that will demonstrate the feasablllty, and explain 
degree of probability of success, before Intensive ia.iaieie.it 3.etno-s 
las described are employed any more extensively. 

Given a favorable market, It Is obvious that accelerated t: 
harvest can produce a local economic "boom". We wish tne .-'Eli to 
offer firm evidence that such accelerated harvest as proposed In 
the preferred alternative, will not eventually result in economic 
"bust". Our concern Is, that In meeting the Immediate timber demands 
of this decade that both our economic and natural environments are 
not "short changed" In future decades. 

In a public appearance last year, U.S. Forest Service Regional 
Forester, Richard Worthlngton remarked that certain Scandinavian 
countries are facing severe timber shortages due to major miscal- 
culations In their allowable cuts. Our total future timber supplies 
should not be predicated on the assumed accuracy of allowable cut 
calculations and high risk Intensive management techniques. If the 
failure of any one of these techniques could leave us with an economy 
below our minimal level of "stability". 

Conservative, yet sound economic advise, Is to never Invest more 
than you can afford to loose. High risk Investments often offer 
the potential of paying the greatest dividends. But If an Investor's 
"sure thing" stocks should go "belly-up" due to unforseen complica- 
tions, then having a remaining nest egg safely tucked away In some 
low Interest paying bank or S4L provides a basic level of security. 

Our old growth forests are such a nest egg. It Is no wiser to 
gamble on our future by liquidating vast quantles of old growth 
In the next decade for the hoped for benefits of Intense "forest" 
management, than It would have been for the Investor to have liquid- 
ated his entire S&L account to assume the same high Intensive money 
management risks. 



104 






16-6 



16-7 



16-8 



2. 

16-9 



So before we. the members of the public, Invest anymore of our 
old growth nest egg In your Intensive management forest Invest- 
ment scheme, we would like you to more fully address some of the 
basic forest Investment questions not yet fully dealt with In the 
draft KIS - This way you can better demonstrate to us, your In- 
vestors, that you are really wise managers and that you 
have accurately accessed both the environmental and economic risk 
you may be asking us to assume. 

The EIS deals very little with the specific Issue of timber man- 
agement despite Its title a nber Management" 
EIS should address the ecological and financial feasibility of the 
various Intensive management techniques as recommended In the pre- 
ferred alternative and discuss the scientific basis by which these 
methods would be applied. 

The EIS does state that compaction from "dragging logs and operat- 
ing ground-based logging equipment", "can reduce the vegetative 
productivity of the soils by 10 to 25 percent" and "compaction and 
reduced Infiltration capacity have been found to last at least 55 
years (tower 197*0 and therefore may last longer than harvest rot- 
ation periods." Also a general prescription Is given for high lead 
I cable yarding vs. tractor skidding etc. Yet the ills seemingly re- 
fuses to question or examine the Justifications for the present 
methods of clear cut timber harvest and the associated machinery. 

It Is as though the public Is to unquestionably accept that the 
BLK applied methods and practices are always best, and the agency 
should only have to deal with the Issue of how much timber harvest. 
Instead of the additional Issue of the ways In which It Is accomp- 
lished. 

Different alternatives of timber harvest methods should also be 
explored to evaluate the possibilities for reduced soil erosion 

I and compaction. How would greater numbers of shelterwood prescrip- 
tions reduce the need for shade cards, brush release, "post-treat- 
ment surveys" etc.? 



The Dais doesn't address these 
told that "an environmental ass 
dress the effect of the harvest 
this way the BLM avoids having 
ltlmate scrutiny. As these are 
also have a say to the methods 
them. What may be the most cos 
be neither the most cost or eco 
by only dealing with these ques 
major policy decisions are not 
ysls or review. 



sorts of questions. Bather we are 
essment of a timber sale will ad- 
method, yarding system" etc. In 
their preferred methods face leg- 
public forest, the public should 
that are employed In harvesting 
t efficient In the short run, may 
logically efficient In the long run. 
tlons on the basis of Individual E.A. 
available for concerned public anal- 



Page 68 of the DEIS states that "the chemical quality of surface 
water would be affected by slash disposal." And "that only Alter- 
native 8 would provide adequate protection for streams." Ihe EIS 



I should further discuss the Impacts to the biological systems of 
first and second order streams of Introducing "fnstream concen- 
trations of ammonla-nltro«en and manganese" that "could exceed 
recommended water quality stnndards." 

3. The DEIS states, buffers "are expected to minimize herbicide 
drift or accidental direct spraying of water bodies" and move- 
ment of herbicides through soil is usually mi of 
Inches or a few feet." Also, "some detectable amounts may reach 
the streams", "due to pilot error", but "planned delivery techni- 
ques would reduce or prevent spray from drifting Into i 
The nature of these statements acknowledges that risks neverthe- 
less exists, and all one can reasonably expect to do Is "minimize" 
problems so they "usually" go as they are suppose to. xTet 
know that on occasion open water bodies are sprayed, or the risk 

I of herbicides carried In subsurface water does exist. To adequately 
assess the Impact of herbicides, some statistical <>:. .Id 

be given of percent error (avoidable or unavoidable) In herbicide 
application. And what are the Impacts on the biological systems 
so affected? 

Also the DEIS mentions how "fast-growing hardwoods, such as red 
alder or vine maple, overtop and suppress slow-startlnf conifer 
seedlings". Yet there Is no discussion of how broad leaf trees 
or shrubs might aid the growth of conifers by providing shade on 
southern exposures. Also there Is no Information on the contri- 
butions of nitrogen-fixation by various species, although studies 
have been done in southern Oregon and quantifiable data exists. 

Fage 76 of the DEIS says "dlesel oil Is sometimes used as a carrier 
for forest herbicides", "however, data are Insufficient to predict 
the Impacts of dlesel oil carrier on animals In the EIS area.' 
on page 87 you state, "phenoxy herbicides as applied do not affect 
birds or eggs unless dlesel oil is used as a carrier." Based on 
this last statement It seems that it would be reasonable for the 
EIS to consider there Is a potential for an adverse Impact on avian 
life as spray operations normally coincide with spring breeding 
bird activities. What levels of phonoxy herbicides with dlesel 
produce adverse effect on birds and their eggs? How does this com- 
pare with herbicide treatments applied In the field? 

Science deals In probabilities. While the BLK currently uses herb- 
icides approved by the Environmental Protection Agency, based on a 
scientific body of evidence that maintains that herbicide use does 
not present any unacceptable human health risk, there also exists 
a certain scientific body of evidence that phenoxy residues do blo- 
accumulate, do move through the soil via leaching, do cause mut- 
ations and cancer and are toxic In lower than measurable amount::. 
Therefore, speaking scientifically, we can neither say that herb- 
icides are totally safe or totally dangerous. Given both confllct- 
lnc scientific bodies of knowledge, we can only conclude that since 
the EM currently approves the use of 2,4-D (supposedly based on 
scientific evidence) as a defoliant, that there presently exist a 



16-11 



-7- 



16-12 



16-13 



greater than 50 •' probability (to the extent there Is more evidence 
for than against) that these herbicides, from a human health stand 
point, are safe. The EIS should therefore address the fact that 
there Is a least some lesser probability that herbicides, as they 
are presently applied, are not safe. The FEIS should more fully 
discuss that the level of risk therefore assumed unavoidably by 
certain members of our population, may not be an acceptable level 
of risk to these Individuals. 

In a report by the Comptroller General of the United States: Better 
Lata .Jeeded To Determine The Extent To Which Herbicides Should Be 
Used On Forest Lands , U.S. General Accounting Office CED-»l-4b, 
April 17. 19B1 It Is generally concluded that the question of ex- 
tent of replacement of herbicide with non-herblclde treatments can- 
not be settled largely because the BLK and Forest Service have not 
kept adequate records of cost or effectiveness, or make comparlslons 
among different sites to determine why certain methods worked on 
particular sites. On page 51 it stated, "The agencies do not know 
the total cost for the various methods used to carry out site 
preparation and release work and cannot, therefore, reliably use 
cost as the major determinant for selecting among alternative 
methods." If this Is the Roseburg BLK's problem the FEIS should 
explain so, and offer ways to begin developing this data. 



'*. The Bureau explains that 200 lbs. of fertilizer per acre will be 
used In portions of the forest with exception of Alternative 7, 
but little data Is given to substantiate Its assumed benefits. 
What are the impacts of forest fertilization? The FEIS should 
16"14 address problems associated with the: 

| a. problems of long term Impact to forest soils. 
16-15' D * consequences of the runoff of nitrogen Into streams. 
jc. Impacts on delicately adapted Improved trees. 
|d. lack of availability due to worldwide energy supplies which 
could get worse. 



16- 16 1 
16^7 



16-18 



What Is the per cent growth gain per acre fertilized and by what 
research Is this substantiated that this technique will be success- 
ful in Roseburg 1 s drier climatic regimes, particularly on south 
facing exposures? Most fertilization experimentation has been done 
on soils known to be low In nitrogen. Because of Roseburg* s low 
rainfall as compared with the rest of the Pacific Worthwest, why 
shouldn't we assume that nitrogen needs are less, as the lower 
rainfall tends to minimize leaching- In fact wouldn't fertilization 
actually Increase the soil moisture stress? Since Roseburg Is not 
like northwestern Oregon, the BLK should produce research on soils 
substantially similar to those proposed for this fertilization 
program, before substantial increases In the allowable cut are 
made, if a sustained yield Is predicated on the success of this 
technique. It is our understanding that, pending further research, 
the Forest Service made a decision not to take allowable cut credit 
for fertilization even in northwestern Oregon. 

Table 3-2 on page 66 estimates that in the next decade under the 



16-19 



16-20 



16-21 



preferred alternative, there will be an additional loss of pro- 
ductivity on 7.872 acres of BLK land. 2,6^7 acres would loose 
their productivity even under Alternative 8. (It seems Ironic 
that these acres be considered part of what the BLK chooses to 
call "Sustain Yield Units" (SYU's).) Ihe draft EIS states that 
total loss of nitrogen from clearcuttlng and slash burning can 
reach as high as 9". But for comparison BLK settled for an ex- 
pected loss of b% nitrogen and phosphorus and a JyC loss of Calcium 
and Potassium. For the four elements this would result In a total 
loss of 6,86l tons in the next decade (Table 3-3)- Would placing 
5603 tons of nitrogen fertilizer on 56.029 acres, at 200 lbs/acre 
(under Alternative <*) , begin to make up for this soil loss? 

If the allowable cut Is figured on the basis that the combination 
of two or more Intensive management treatments (I.e. first fert- 
ilizer then thinning) will double the rate of growth, and there- 
fore permit a larger annual cut, what documentation Is there that 
this sort of "piggybacking" will in fact produce the anticipated 
extra Increase in growth? An analysis of any such assumptions 
should be made in the EIS If the combination of two or 
practices Is assumed to result In any greater growth than If only 
one practice Is employed. 

Under the preferred alternative 333,319 acres will result In 
trees with a minimum harvest age (HHA) of 50 years. The FJS 
should address If the benefits gained by harvesting trees at 
this younger KHA, would outweigh the long term cost In loss of 
superior saw timber found In trees In excess of lb.lt Inches dbh 
were these trees not harvested before they reached greater matur- 
ity. Also would such a policy be In compliance with the 04C Act's 
requirement of providing "for permanent forest production"? 

Ihe EIS states that "target stocking levels of 2^5 to 320 trees/ 
acre cannot always be achieved by the Initial planting." £ven 
with "post-treatment surveys", of the Roseburg District's 391,100 
acres of commercial forest land, how many acres are currently un- 
stocked or under stocked? How will additional Intensive manage- 
ment practices alleviate or contribute to this problem, If these 
problems have not met with solutions under present practices? 
Have any growth studies been conducted on Roseburg zU. lands to 
show that these techniques are successful under your particular 
set of environmental circumstances? 

In terms of site preparation, what assumptions are being made that 
a certain per cent of natural seeding will serve to make up for 
stocking failures? It must be recognized In the EIS that with 
the proposed rapid rates of cutting, that stands that provided 
gratuitous seed will soon be gone. What assumptions are being 
made as to how many units will require replanting? Is good site 
preparation an assumption on which the allowable cut Is based? If 
so, the EIS should analyze your site preparation problems. 

-Jg-23 6 -li° what extent Is the projected Increase In the allowable cut 



16-22 



-9- 



16-23 



16-24 



16-25 



16-26 



16-27 



16 



dependent upon the use of Improved genetic strains of trees? 
The EIS should assess the probable success that can be expected 
to be met given the Inadequacy of research that has so far 
occured with their use. Also the EIS should assess If this Is 
really a viable technique for Increasing production as the tree 
Improvement programs, as required by Instruction Memorandum 
0R-79-334. are at this time behind schedule. 

One Justification offered by the Dais for "the eventual planting 
netlcally Improved trees on 90 percent of the Intensive tlm- 
nductlon base," Is that "maintaining a broad selection of 
parent trees would ensure variability In genetic populations". 
While this might Insure "variability" It can't replace the 
specific genes of those tree species that were adapted to those 
site specif iciocatlons. Also It Is offered that "bLi\ administers 
29 percent of the total forest land's." Is this meant to Infer 
that the other ?1 t can be assumed to provide natural stock? It 
should be expected that adjacent land ownerships will also adopt 
similar Intensive forestry practices. 

We agree with the DiilS that until "the symbiotic relationships 
between plants and animals that function In old growth stands" 
are "fully understood" It Is Important to maintain "a representa- 
tive range of the old growth forest and associated floral and 
faunal genotypes." We take strong exception that "all alternatives 
except Alternatives 1,2 and 5 would provide adequate representation 
of the original old growth systems." This Is an Incredible state- 
ment, when other parts of the DEIS acknowledge that most other old 
growth dependent species will be reduced below viable, self-sus- 
taining levels except for Alternative 8. 

Special area designations such as ACEC s, RMV's and outdoor ed- 
ucation areas will comprise no more than .7/-' of the forest under 
any of the alternatives. The proposed old growth Bear Gulch MA 
recommended by the Federal Research Jatural Area Committee, has 
not only been dropped but Is not even mentioned In the EIS. Ihe 
acreage of the proposed 480 acre Jorth Kyrtle RNA has been cut 
In half. We ask that this acerage be restored to the full uncut 
480 acres as It was previously represented by the BLr. and 
recommended by Dr. Jerry Franklin and the Research Natural Area 
Committee. 

We take exception to the statement that the preferred alternative 
Is consistent with Statewide Planning Goals number 4 and 5« Ihi 
liquidation of our old growth as envisioned in the preferred alter- 
native would not be "to protect" this "natural and scenic resource". 
Slmilarily It would not serve "to conserve forest land for" old 
growth "forest uses". 

|4.5,t of the Roseburg BLM District Is in public domain lands and 
subject to different laws. Ihe ownership is, in Itself. 
Justification for true multiple use and wildlife habitat retention. 



16-30 



16-31 



105 

Under the Endangered Species Act of 1973 It t all 

I departmenl 1 seek to conser- 

species ind I - orltles 

in furtherance of - ; s of this Act." lable 3 of th 

.-.mary Broc ore can be 

to enhance the habitat of 
then propoj 
land allocation, that would only serve tc mount 

ting eagle habitat, 
your "authorities in furtherance of t! -:t." 

I-rotoctlng bald 

additional h Lded to encourage at least s 

reestabllshment of pr-vlous historical populatlc: 
you assure, 

inly small population. location foi 

i.dll Ulini 

their obligation 

s that construction of ne 
to harassment of wildlife and r ge carnivore 

habitat witln one-half mile of these road 
of roads mean more access by hm 
is probable." Also, "Adverse Impacts to el^ would occur 

78 you stated , "1 h 

be affected only to the- extent that road construction cou 1 

previously unaccesslble areas. itlfled 

or qualified." If it con be "qualified" for ot 

that it 

why should' nt the same i, and thus 

and endangered species? Also th 

within eagle nest sho 

alternatives, why is it unreason 

more llkel; In the lone run If an alternative ot 

were selected'' 

Ihe CEIS states that an "envlronm 
. peolflc action, 
la Dies known to be present on the sit 
I measures to be taken." Ihls doe? not address t 
ened on>' endangered species may very well not bi 

ivlronmental analysis" (i.e. the plant is not in bloom) an" 
I therefore inadvertently destroy 

In western Oregon about 30 secondary hole nestln 
pendent on 14 primary excavators to provl ' 

in which to nest ( Ihe .ieed For '..'lldllfe a-lt-t llv. -■ '■ 
On PL,, - ■■.anaged forest Lor,' In Western Cre- — . • - __. 
"to manage primary excavators at the 5o ercent 1 v.] 
? safe level) requires two 

"only Alternative 8 reaches I 1 svel alt--. 

Alternatives 6 and 7 ercent 

lent level accord to Table 3-10. 
be to liberal, as the old Alter:. 



was within 3 and 4 KH3I of Alternatives 7 and 6 was previously 
described to offer only "a cavity dweller population at 40 ■ of 
maximum potential throughout the District". According to Jack 16 - 32 

rhomas, 'lldllfe Habitats In l.anaged Forest , 40: is the 
very bottom of the "viable" range. Ihls level of cavity nester 
population would be dangerously close to not being able to main- 
tain self-sustaining populations. We therefore can not feel com- 
fortable In your conclusion that Alternatives 6 and 7 are "close" 
enough, especially when "District surveys regaled that snags and/ 
or wildlife trees are being provided at the rate of 0.1 per acre 
on recent harvest units." 

-cent Solicitor's review has stated "that the OiC legislation 
is a conservation measure requiring a form of multiple use manage- 
ment" and "further, the Act clearly does not mandate exclusive use, 
but Instead requires management for other Interest as well as tim- 
ber supply." The Law of i.arch 29. 1944 further solidifies 3L;.'s 
commitment to multiple use management. Ihls lav; provided the Sec- 
retary of Interior with the authority to set up cooperative sustain- 
ed yield units to among other things "secure the benefits of forest 
in. . .preservation of wildlife..." (16 U.S.C. 583) Yet In recom- 
mending the protection of only 18 pairs of northern spotted oi 
to be maintained (under the 30C "cro prescription) of the 55 pairs 
known to presently occur on the district, BLM has ione an 
job at fulfilling It: oal to keep the spotted owl off I 
federal endangered list. 

lollcltor's : tes: "In the case of those areas of land 
direct conflict in use will occur, the bureau may choose one 
use over the other, provided It has analyzed its choice in the eon- 
text of the principle goals of each Act and is satisfied that the 
particular choice has not significantly encroached upon the overall 
effect of those goals." pnrtment of Fish and 

life has stated that Roseburg' s contribution to the Spotted Owl 
Management Plan is essential in providing a connection that will 
assure genetic vlablllv . spotted owl populations on the 
coast and in the Case recommending less habitat (and 

number of pairs) for spotted owls In your preferred alternative, 16—35 

then was recommended be provided by the Endangered Species Task ,w ^ 

Force, you will be severiy Jeopardizing the viability of this 
species. Any alternative which would reduce existing old growth 
on the Roseburg District from 110,900 remaining acres to Just 
28,400 in Just three decades is clearly a "significant encroachment 
upon the overall effect" of this particular multiple use goal. 

In Pabltat Diversity For Wildlife On 3LH nanaaed Lands In Western 
Orejon (revised October 1981) It is stated that If 15,. of PL:. 
lands were retained In mldage and old growth forest, minimum 
habitat diversity requirement could be met. Yet out of Roseburg 
eiLi.'s 424,000 managed acres, all totaled, less than 9f (38,000 acres) 
would be provided as habitat, in the preferred alternative, for 
species which prefer old growth areas — countlns scenic corridors 
and marginally protected stream buffers. As this Is wholly un- 



acceptable to us, :ore full; your 

choice" and ssue of how these less lounts 

of acreage '.rill "secur . Pits of for . . - tlo.n 
lldllfe"? 

address the follovln. question! 
« on Ithe nortiurn spotte- : owl. What does t 
ID OO | *, -.. (or 

lack of it' with the Department of 
recommendations of the En . - 

: 



. e shown the 
r until 

ot th"! 

llity to " 

i 
rotation than th. 

continually provl 



16-3 



. 

er acr 

acre? 
f.e of 

Iso 
I 



4 



on i able ')-■ , '•... 
Land (To ' 

native ■'■ . 
1 thru result in 

■ 
. 00 tons, o! 
In our .: 

llty prob: ,. 
re sedimentation (13 out of 17); 
temperatures (16 out o: 

Sow can the SLi: claim that Alternatlv 

nlflcantly less 
tons/decade, a difference of 4,40? tonsl :iow can cal- 

culate the difference t el of con- 

fidence to enable your claim? Especla] ju concede 

Le soils are found throughout th 
that "these soils Include 3?. ranltic soils or other 

soils that ntial for mass failure and 135,711 

acres of soils on very stee 1th Inclusion of unsta 

Us."* Yet the preferred alternative would commit 333.319 
acres of commercial forest land to Intensive timber management 



Ls totals 172.253 acres of unstable soils. If this is sub- 
tracted from BLI.'s total acreage of 424,000, 251, 74^ acres of 
stable land remains. This is interesting to cr the 

262,436 acre timber base recommended under alternative 8 that 
would still produce 84 ,.,-.3F per year. 



106 



-13- 



16-36 



16-37 



and an additional 52.2**? acres to be managed under what Is 
called "modified area control" — (which still permits timber 
harvest In riparian buffers). Studies on I 
District show that landslides In Tyee sandstone Increase- 

•ibove the undisturbed forest rate following clenrcuttlng 
and roadbulldlng (according to the DEIS). Yet according to the 
BLl'.'s 5 year timber sale plan, "4600 acres of these soils, ldent- 

18 fragile, would be harvested." 

It Is ridiculous to assume that Alternative 4 will produce as 
positive gains for fish populations in comparison with Alternative 
8 — the letter, which by your figures, wouldn't even produce 1/10 
the sediment load. Also "should design features fall, portions 
of streams could be adversely Impact. Is their probability 

of failure? Aj-._ the tons of sediments per decade for each alter- 
native figured without including the additional Impacts of possible 
failures? 

Under "environmental Consequences" page 77. the author attributes 
the impact of timber management on fish populations and discusses 
the Importance of maintaining buffers to protect "the habitat of 
aquatic Invertebrates, which are Important both as food for fish 
and as Indicators of stream quality." "On lands administered by 
BLK in the SYUs there are approximately 270 miles of streams that 
support cold water fish." Analysis of the sample 5-year timber 
sale plan shows that approximately "17 miles of stream that sup- 
port cold water fish pass through or are adjacent to 77 harvest 
units." The author falls to draw the obvious conclusion of what 
additional affect stream warming will have on fish populations 
under the preferred alternative. The conclusion on page 79 how- 
ever states, "If it is assumed current fish populations reflect 
conditions and harvest regulations over the past decade, then It 
can be assumed that fish populations would decline under Alter- 
natives 1 through 3 due to Increased teaoeratures and sedimentation." 
"Fish would Increase In Alternatives 4,6,7, and 8 and remain the 
same under Alternative 5." 

It Is hard to see how they will remain the same under the No' 

Alternative 5 "If It Is assumed current fish populations 
(which are not high) reflect conditions and harvest regulations 
over the past decade" and as explained on page 78, since Alter- 
native 5 makes "no provision for riparian buffers" .. ."water 
temperatures would increase greatly." On page 68, the forcasted 
sediment loads of Alternatives 6 and 8 don't even come close to 
the magnitude of other alternative's sediment loads. Including 

ntlves 4 and 7. It is difficult to see how either Alternative 
4 or 7 coul ted to provide fish populations that would do 

anything but decline. It Is amazing that BLii thinks that a sediment 
load of 281,300 tons (Alt. 3) will decrease fish populations, but a 
a projected sediment load of only slightly less (272,800 tons under 
Alt. 4), will Increase fish populations. On page 18 It states 
Alternative 4 allocated the same acreage to timber as Alternative 3. 
Also "management elements would be the same as Alternative 3" — 
under which "fish populations would decline." 



16-38 



12. The SIS states that "Alter,, tl -ovldes temperature aal • 
ror first order and larger str . ,-. -natives 1 

removal of merchantable timber would reduce thi rieao of 

buffers to provide adequate shade resulting In lncr 
tures." Also "downstream shading do- Iflcantly lower 

temperatures of streams warmed by upstrea . al. 

1971)." Since the tons of'Sedlment Produced Through prop,. 
In lable 3-5 Is only again slightly less for Alternative 4 than 
Alternatives J and 5, why should „e not also assume that Alter- 
natives 2, 3 and 4 will also raise stream temperatur ;iy 
the data shows that the magnitude of this Impact will be even 
greater In Alternative 2 than 5? 

Also we would expect fish success to decline under the preferred 
alternative because "oxygen concentrations In stream gravel may 
continue to decline for several 

flow through gravels Is restricted by sedimentation (.-all and Lantz 
19&9)." And, "for this reason, Impacts on lntragravel oxygen in 
the SYU's would be directly related to the change In sediment s 
discussed above" ( pa^e 69). 



Also this same sediment yield, which 
the natural rate (undisturbed condlt 
with roads (Fredrlksen and Karr 1979 
any measurable increases In summer 1 
research done by Denlse :;arr of the 
you can't count increased low flows 
increase In flows are going to be le 
on the larger streams, and will be 1 
uatlon of the larger streams. 



to be "23 tl 
Ion) in a patch cut waters! 
)" , could absorb and contain 
ow flow levels. According to 
Forestry Science Lab in Corvallls, 
as a benefit. Any hypothetical 
ss than your ability to 
ess than the year to year fluct- 



13- Other research by Pedell, Everest and swanson at the pacific .iorth- 
west Forest and liange Experiment Station have E "-uldellnes 
for future practices that will best preserve and restore both physical 
and biological Integrity in streams ecosystems" ( Fish Habitat and 
Streamslde ,,anagment fast and Present ) . Four key structural com- 
ponents are to provide "(1) large live trees In riparian zones, (2) 
large snags, (3) large logs on the flood plain, and (4) large snags 
and large organic debris in the stream." "Organic debris in streams 
Increases diversity of aquatic habitat by forming oools and protected 
backwater areas, serves as a source of nutrients and substrate for 
biological activity, and affect sediment movement and storage by 
dissipating energy of flowing water and trapping sediment."' 

Alternatives, other than #8 would not provide these conditions. 
Page 75 of the DEIS states that "management by modified area control 
as proposed In Alternatives 2,3,4 and 7 would. . .substantially alter 
riparian habitats." 

Of the Hoseburg BLi'.'s 424,000 acres only 22,800 acres consist of 

riparian habitat yet "riparian habitat is Important as 88 percent 

of the terrestrial wildlife species in the area use it to some degree." 



-14- 



-15- 



16-39 



14. 

16-40 



Yet in seven out of eight BLK alternatives buffers are provided 
only along streams (200 feet wide in most cases) that are third 
order or greater. According to the DEIS this makes up only about 
3 percent of the forest land base." An additional 12,150 acres of 
small first and second order streams would only receive protection 
under the Full Ecosystems Alternative, Alternative 8. In addition, 
page 45 of the DEIS concedes, that even along 3rd order streams 
"some of this has been altered by past timber management practices 
and Is In less than optimum condition." 

Oregon Administrative Rules, Chapter 340, State Water Quality 
Law for the I'mpqua Basin and the Clean Water Act of 1972, as 
amended, specify that no temperature Increases are allowed on 
streams that are above 58° Fahrenheit, and federal agencies are 
bound to that state standard. How will the preferred alternative 
prevent temperature Increases when Table 2-5 "Severe '.later Quality 
Problems" Indicates that 16 of 17 major streams in the Hoseburg 
District already have "elevated water temperatures?" Sediment 
yield or turbidity is limited to 10S Increases — how can full timber 
harvest be allowed on first and second order streams with the 
Increased possibility of landslides when roots die in seven to ten 
years? 

In the FEIS please provide some explanation of the allowable cut 
calculation. What assumptions must be made to Increase present 
harvest levels? If any assumptions are being made which lack 
sufficient documentation, then the FEIS should explain the rational 
for using these assumptions. 

I What would be the cost-benefit ratio for various intensive manage- 
ment practices If you did not take a credit for cutting existing 
old growth, but rather figured the allowable cut effect (ACE) Just 
assuming reforestation alone? 

A risk factor should be figured Into calculating the allowable cut. 
The FEIS should state what the risk would be for: 

a. drops in biological potential due to fire or disease. (The EIS 
should also describe what forest diseases presently exist on the 
Roseburg District.) 

b. drops in biological potential resulting from overly optimistic 
projections of growth increase resulting from intensive management. 

c. inability to carry out management programs because of financial 
squeezes or contract failures. (If a key assumption of the allowable 
cut calculation Is that sufficient funding and personnel will be 
available for the lmpllmentatlon of the final decision, then the 
FEIS should Include a list of priorities should funding fall below 
the accustomed levels.) 

Table 1-5, "Summary of Impacts", provides a somewhat distorted 
picture of net Job losses. Besides being based on a set of 
assumptions not fully explained in the DEIS, future employment 
pictures might be more accurate if they were based on present 
trends In the Industry for the entire southern Oregon area coupled 
with the reality that the "building boom" days, facilitated by low 
mortgage rates, are gone. Also, if Instead the per cent of total 



16-42 
16-43 

16-44 



Job losses from BLK alternatives were compared with projected 
declines in all areas, a more accurate picture would be portrayed, 
rather than to basically Just single out BLr.'s contribution. 
Previous studies have shown that the southern Oregon counties 
are net exporters of timber. Apart from the present recession, 
as long as mill capacity is above supply, there will be Job losses 

I in the timber industry. The FEIS you write should acknowledge 
these facts and estimate what the Job potential would be If more 
of this timber, presently exported, were kept cycling through 
the local economy. 

15- We find the discussion of Impacts on recreation ludicrous. The 
DEIS states that "opportunities for such activities as camping, 
hiking, fishing, hunting, nature study and slghtseelnj would be 
degraded in some areas." Yet "clearcuttlng" somehow balances 
this by providing "opportunities" for " olcknlcklng" , "using ORV's" 
and"provldlng openings for scenic views." r.aking a clear cut to 
provide a scenic view, would be like blowing a hole In the roof 
of your living room, to better facilitate seeing the stars. 
Furthermore, there are presently 12,000 acres of roads on the 
Roseburg BLK. This Is presently more acres of roads than Alter- 
native 5, the .io Change Alternative, would provide In acres of 
old growth in Just a little over 20 years (see Table 3-9 page 73). 
In addition the DEIS states "In Alternatives 1,2,3, & 4 road 
building during the decade would be more than in the past decade." 
It seems the ORV opportunities are going to be more than adequately 
provided for in proportion to opportunities for hiking and nature 
study In an aesthetlcly pleasing environment. Ihe DEIS's reference 
to clear cuts providing "plcknlcklng" oportunltles does not deserve 
further comment. 

We also resent the assumption that "some visitors may relo- 
cate to other areas where opportunities for desired experiences 
exist." The point Is, at the rate we are manipulating and alter- 
ing our forest and other natural places, there will simply be few 
places left to go where the hand of man hasn't already marred the 
earth. We disagree with the statement on page 81 that "Alternatives 
2,3,4 and 7 would be satisfactory "In meeting the demand for hiking". 
Especially when you lump the hiking experience with "horseback 
riding and off- road vehicle areas and trails." Also, some horse- 
back riders may prefer bridle trails that offer a greater aesthetlc- 
ly pleasing experience than what can be afforded. In the above 
mentioned alternatives, from a tractor road through a clear cut. 

Our forests should be managed, but not exploited. We need to re- 
move forest products to meet human needs, but not at the total ex- 
clusion of all other creature's needs. Both house of Congress 
recently demonstrated their concern by an overwhelming unanimous 
reauthorization of the Endangered Species Act. We don't believe 
that the American public, represented by our Congress, accepts 
the management of our forest's resources by an agency whose manage- 
ment direction openly Implies and reports the future degradation 
of our wildlife, our watersheds, and our remaining old growth 
forests. 



-16- 

Slncerely , 
Umpqua Valley Audubon Society aoard of Directors 



107 






0\ Qiyv%AMC^>j6U^v^x-^ 



Response to comments in Letter 16 



16-1 No allowable cut credit is tak 

manual release methods of vegetation control. Refer to DEIS, 
Appendix C, Allowable Cut Effect, page 127. Also, see i 
cannon issue 3. 

16-2 Alternative 4 in the DEIS is tl 

MFP preferred alternat. <■ 

difference in volume is the r 

the allowable cut calculation. 

16-3 Alternative 8 is the wildlife alternative which in 
allocated for int t management | 

Appendix C, Table C-2. 

16-4 The Roseburg District Young Growth Management Cam 
(available at the Roseburg District Office), add: 
management techniques incorporated in the Roseburg D: 
along with rationale, assumptions and lit i 

gains associated with such practices are represented by DFIT (see 
response to comment 16-20). Scheduled monitoring will examine 
of intensive practices as described in the DEIS, Chapter 1, p ■ 



16-5 The harvest level for all alternatives is computed to be sustainable 
for 400 years. Refer to DEIS Appendix C, page 127. Fish 
recreation and other water dependent activities are expected to be 
sustainable. 



16-6 See response to comment 16-3. 

16-7 See response to comment 5-1. 

16-8 Timber harvest method alternatives and their influence on soil 

erosion and compaction are discussed in detail in Chapter III 1975, 
Timber Management Final Environmental Impact Statement, incorporated 
by reference in the EIS 

The silvicultural validity and cost effectiveness of clearcutting and 
intensive reforestation vs. shelterwoods are discussed in a Roseburg 
District study, "Use of Artificial Shade to Increase Survival of 
Douglas-fir in the Roseburg Area" (Wert and Lewis 1977). This study 
is available for review at the Roseburg District Office. 

16-9 In the Roseburg SYUs first and second order streams are normally dry 
except during peak flow periods. Nutrient concentrations following 
slash burning will normally not exist during flow periods- therefore, 
impacts to water quality are not significant. Also, see text revision 
in FEIS, Impacts on water Resources, Water Quality section. 



16-10 The Roseburg District has been monitoring herbicide operations for 
several years. This includes testing a number of water samples. All 
of the test results have indicated either no herbicide residue or 
levels of herbicides well within set standards. Results are available 
at the Roseburg District Office. 

16-11 The statement on page 87 of the DEIS was in error and has been 
removed from the FEIS. 

16-12 Evidence examined by EPA in the 2,4-D registration 
recently summarized by Frank Dost et al . (SQCATS 
Court in Portland indicates no significant human health hazai 
silvicultural application of 2,4-D. This finding has be 
by Drs. Melvin Rueben and Ruth Shearer, both of whan believe that any 
human exposure to 2,4-D, regardless of how smal the 

amount, presents a significant hazard to human health. 

16-13 Roseburg District has conducted several cost studies associated with 
vegetation management practices. Data are currently being collected 
for each vegetation management practice. These data are being used in 
the new Vegetation Management EIS, scheduled for completion later in 
1983. 



16-14 Long-term impacts to forest soils were judged to be insignificant 

because the nitrogen increase caused by fertilization will readily be 
eliminated by plant adsorption, volatilization and microbial action. 



108 



16-15 See response to ocmment 15-7. 

16-16 Impacts from fertilization on genetically improved trees are 

presented in the DEIS Chapter 3 Impacts on Vegetation section page 
70. No adverse impacts on genetically improved trees are expected to 
occur 

16-17 Same recent forecasts indicate that energy supplies may be abundant 
for years to come. 

16-18 The Regional Forest Nutrition Research Project has been studying the 
effects of forest fertilization in southwest Oregon for over 10 
years. There are seven study plots in the BLM Roseburg District. This 
research project is being conducted by the Pacific Northwest Forest 
and Range Experiment Station and the University of Washington. 
Results of the study indicate that cubic feet/acre/year increases in 
tree growth commonly exceed the 11 percent gains in the district's 
allowable cut model. Additional information is available at the 
Roseburg District Office. 

16-19 Fertilizer application, according to the district's management 
regime, would not replace the volume of soil nutrient loss from 
clearcutting or burning; however, fertilization provides an average 
timber volume increase of 11 percent over natural production yields. 
Thus, overall soil productivity is increased over natural levels 
through fertilization. 



16-20 The concept of "piggybacking" intensive practices ia controversial. 
This controversy steins from a lack of research on the cumuli 
effects of applying various combinations of intensive practices to 
stands of varying site quality over the length of a harvest rotation. 

Although long-term research is lacking, research of shorter duration 
has produced much data. The authors of DFIT feel that data I - i 
short-term research can be safely extrapolated into the future. (DPIT 
is the managed Douglas-fir stand yield simulation model developed at 
the USFS Pacific Northwest Forest and Range Experiment Station to 
project future growth under various intensive management schemes.) 

In developing the DFIT model, the best available information was used 
to simulate the combined effects of intensive practices. BLM has 
adopted DFIT, with certain adjustments, as an acceptable estijnator of 
future managed stand yields. Also, see response to common issue 3. 

16-21 Refer to DEIS, Appendix B, Table B-8. The analysis of differing 
minimum harvest ages notes that under most conditions, the net 
present value of the forest decreases with an increase in minimum 
harvest age. Yields displayed in all alternatives are sustainable. 

16-22 Two thousand two hundred twenty-six (2,226) acres of recent clearcuts 
awaiting site preparation are currently non-stocked. Four hundred 
sixty-seven (467) acres of brush and hardwood conversion areas await 
initial planting. Five thousand fifty-nine (5,059) acres of partial 
reforestation faUures are currently understocked. These 



reforestation delays, as well as successes, are accounted for in the 
"Reforestation Lag" time input to the allowable cut calculation. 

Many studies specific to the utility of the proposed intensive 
management practices on the Roseburg District are cited in the Young 
Growth Management Committee Report (1979b). Additional local studies 
attesting to the effectiveness of the practices are available in the 
district office. 

One hundred percent planting of harvested lands is planned. 
Gratuitous seed from an adjacent source is not necessary to achieve 
district goals but would certainly contribute toward reaching the 
stocking standards if it occurred. 



16-26 The Research Natural Area Committee originally identified the Bear 

Gulch parcel as a needed cell for the western Cascades physiographic 
province. The committee later indicated the cell was within the 
Klamath Mountains or Siskiyou province, for which the Roseburg 
District has no responsibility. 

16-27 See response to comment 5-2. 

16-28 BLM's conclusions regarding consistency with Statewide Planning Goals 
were developed through consultation with Department of Land 
Conservation and Development staff. 

16-29 See response to comment 7-1. 



Good site preparation and site maintenance are requirements of a 
successful reforestation program. 

16-23 See response to common issue 3 and comment 4-3. The Roseburg District 
Young Growth Management Committee Report addresses the viability of 
the tree improvement program. 

16-24 BLM has made no assumptions as to reforestation methods on adjacent 
private lands. Appendices E and F illustrate that BLM plans are not 
going to significantly alter stand structure in the EIS area, as 
related to the tree improvement program. 

16-25 See revised text, FEIS, Chapter 3, Impacts on Vegetation section, for 
a more comprehensive discussion of this issue. 



16-30 The effect of the transportation system on State-listed species can 

be quantified to the extent the given alternative provides protection 
for selected owl pairs. The primary effect on the spotted owl would 
come from harvest unit placement. Because road development is part of 
an overall harvest action, roads are assumed to affect the owls in 
the same manner as the harvest units when in proximity to owl 
habitat. 

With regard to federally listed species, i.e., the bald eagle, it is 
assumed that compliance with the Endangered Species Act and the 
development of Habitat Management Plans (on the lands allocated for 
the eagle) will assure that no adverse conflicts between the 
transportation system and the species habitat will occur. 



109 



16-31 Every effort, including appropriate season field examinations, is 
made to become reasonably certain that there are no impacts to 
federally listed threatened and endangered plants or those under 
review for federal listing. Guidelines for botanical surveys are 
given in Instruction Memorandum Roseburg 81-22. 

16-32 As stated in the DEIS, Chapter 3, Impacts on Animals section, not 

every alternative may provide habitat for all wildlife species in the 
long term. Also, see response to cannon issue 1 and comment 12-1. 

16-33 Based on the direction provided in the the new O&C Forest Resources 
Policy (Appendix A), the BLM will not actively pursue a management 
plan to yield any specified population level for spotted owls. 



16-35 Conclusions on sediment yield for each alternative are compared 
against the existing situation. Alternative 5 represents data 

loped from the previous planning process, which is not 
necessarily comparable with this plan. Based on 

calculation. Alternative 4 is determined to ■ •rimental than 

Alternative 5. However, the degree of significance and level of 
precision are difficult to calculate with a high level of con! 



16-36 The probability of failure cannot be precisely 
properly designed and constructed pro: 
failure. Specific practices are subject to char 



xi mon 



and results of new research. Th roth the DEIS 

and FEIS does not address the possibility of design fail 



An assessment of the effect this approach has on species viability 
statewide is included in the FEIS, Conclusions section. Chapter 3, 
under Impacts on Animals. Also, see response to comment 83-6. 

16-34 The conclusions reached on page 79 of the DEIS, Table 3-6, are based 
on changes in temperature and sediment compared to the existing 
situation. 



16-37 The text has been revised to indicate that a vegetative buff 
be maintained in Alternative 5. In the EIS, Alternative 5 is 
considered to be a continuation of the plan for the 1970s and a 
reflection of the existing situation. Research by Hall and Lantz 
(1969) indicates that increases in fine sediments to spawning beds 
can decrease the permeabil ity of spawning gravels, af f^ - 
survival of salmonid embryos and impeding emergence of fry. Increases 
in sediments over the existing situation {Alternative 5) would result 
in decreases in fish population, while decreases in sediment from the 
existing situation (Alternative 5) would result in more favorable 
habitat capable of supporting increased fish populations. Prom this, 
it can be assumed that fish populations would be greater in 
Alternatives 6, 8, or 9 than in Alternatives 4 or 7. 



16-38 Buffers for sediments and for shade are two separate things. Shade 
over third order and larger streams is provided in all alternatives. 
Because Alternative 1 permits timber harvest in the streamside 
buffers which would reduce shade, stream temperatures are expected 
to increase under that alternative. Harvest in riparian areas on 
first and second order streams is not expected to increase 
temperatures as those streams are usually dry in the summer. 



16-43 Yield projections for intensive management practices are based on 

current research and are adjusted to operational levels. Yield gains 
from intensive management practices are reduced to account for 
physical variables which differ from controlled research and which 
are below ultimate biological potential. These factors are bui 
the allowable cut computation (refer to DEIS, paqe 127). Also, see 
response to comments 16-22 and 16-23. 



16-39 Chapter 340, State Water Quality Law, states that forest management 
activities shall be in accordance with the Oregon Forest Practices 
Act. Also, see response to comment 15-6. 

16-40 The allowable cut computation process is discussed in the DEIS, 

Appendix C, page 127. Prescribed management treatments are described 
in the EIS, Chapter 1 and summarized on Tables 1-2. Also, see 
response to common issue 3. 

16-41 There is no allowable cut effect for reforestation alone. Refer to 

DEIS, Appendix C, page 127 for discussion of the Allowable Cut Effect 
(ACE) . 



16-44 See response to common issue 2. 

16-45 Table 2-17 of the EIS reports rates of change in lumber and wood 
products employment for Douglas County, the regional economy 
(Douglas, Lane, Coos, Josephine, and Jackson counties) and Oregon for 
the period 1972-1980. The text on page 54 of the DEIS cites I 
reports which make projections about employment in lumber and wood 
products manufacturing. The FEIS displays the impacts on the human 
environment of an array of alternate timber management programs 
available to the Roseburg District of the Bureau of Land Management. 
It is beyond the scope of the FEIS to evaluate alternative federal 
policies on international or interregional log export. 



16-42 In the event of a natural disaster, such as fire, blowdown, disease 
or insect attack, the salvable volume harvested would be substituted 
for the normally planned clearcut volume. No other safety or risk 
factor is built into the allowable cut determination process. 
However, if a disaster were extensive, a recalculation of the 
allowable cut could be made before the normal 10-year recalculation. 




i d States 1 >epartment ol the Interior 



1202-03 (PNR-RE) 

Roseburg Timber Management 

DEIS 

August 12, 1982 



\A1 II IN \l PARK SI K\ II I 
Pai iih Northwcut Region 



32 



Response to comments In Letter 32. 

32-1 Ihis kind of analysis would be applied to Individual timber sales and 
detailed in environmental assessments when such conflicts are 
identified. 



To: District Manager, Bureau of Land Management, Roseburg District 
Office 

From: Associate Regional Director, Recreation Resources and 
Professional Services, Pacific Northwest Region 

Subject: Roseburg Timber Management Draft Environmental Impact 
Statement 

Our comments on the subject document are provided below: 

The proposed protection of cultural and/or historic resources is very 
satisfactory. However, we have some concern about the way in which the 
impacts on recreation are described. It is stated that "timber harvest 
in the vicinity of potential hiking and equestrian trails would degrade 

I the recreation experience ..." While this may be so, it might be 
stated that if timber harvest is planned in the vicinity of potential 
hiking and equestrian trails, attempts will be made to keep the impacts 
upon the recreation experience to a minimum. 

We realize environmental assessments will be prepared prior to each 
timber sale and that these documents will provide more specifics. We 
will look forward to reviewing the assessments. 

Thank you for the opportunity to comment. 



/£j*uL£ft£fc- 



Richard L. Winters 



33 



-2- 



^1 chard Chasm 
P.r. Pox 51 
Dlllard C=, 9TW2 
16, Aug. 1982 

Kr, Jim Hart, District .-.anager 

Bureau of Land hanage:, 

.,. Garder Valley Blvd. 

Roseburg OR, ,: ^4 7 C 

Dear Kr. Hart, 

After several weeks of careful reading and study of the 
. a-ao-eme-t Draft SIS, lifould like to submit the 
following comments. I realize at the p-ese"t tltre we'dlscusslm th» 
adequacy of this document to prepare the final 51? Borne time - ext year. 

After years of nlar'lna document? from the county, stat<> a* 1 
Forest Service, this BU. booklet Is quite refreshing. The olan'-lnu 
effort and resulting text, I feel Is ge-erally to be commended fcr 
presenting a series of choices and then honestly examining the co-Tllctn 
that each choice entails. Ae- or» remembers the BLK of 5 or 6 years 
Is clear you folks have come a lo"« way. 

Since the final SIS will be the basis ror dec'sln^o we will 
live with fcr ten Important years, a careful - 1 1 sous- lor of the facts 
and full economic ;onsequences of cur decision Is -eccessarv. Whatever 
qua: Draft EIS "s° there are als- several important 

flaws *. Is oerfect, hcwever the I = = 

are sr fundamental the average citlze' sould be misled eas! 



This document displays a thorough grasp of the lustry 

economy a-d the standard Justifications of that ecoroi «'■ 

economies of the forest other than logging are i"°s» r '^ the ~' r — 
becomes vague a d the ha-dllna clumsy. Notice the of1 me - 
Alturratlves 1,2,3,4, i 5. These are rea = ';»« of 

subtly and variation the timber management eH of * 

The remalnl g three alturn-i t' ves are cruno lump!) tn«t are dlff! 
to divide Into their finer points that they might be 

of the first five. While all oc"!fllctl g Points are wrltte' down, fie 
overwhelmli.g bias Is to Increase the allowable cut. Thl = Is 
surprising, It Is also displayed cor.slstantly , asal-- and ao-al- throutrhnut 
this documert. 

Basically this EIS plays off the money to be made clear 
cutting against the birds and the bees a'd the f ' sh . As the "A 
Oregon continues to emphasise the tourist attractions of this area the 
monltary values of clear water, "^od fishing a>-d prist' »e vl=tas will 

I be Increasing, Indeed such thloos are orlceles=. Yet ir this Draft EI? 
■ 
tourism a-d the fisheries are grossly underestimated. Th- 

33_2|Umpqua River Is not rated asVClas? I scenic area for exarrnle. 

II ;- 1 far more sophisticated analysis of * 

resources and their sccncmlc value, 'iuch a- analysis mlo-ht 'hew the 
short term benefits of clearcuttlng are wiped out by the lor» term 
value of old growth, the non-timber multiple uses and the co't of 
loss of productivity due to erosion. 

Another fundamental shortcoming of this document Is the 
assumption that "Timber harvest under all alturratlves would be 
accomplished predominately by clearcutt 1 ng . " 



33-4 



33-5 



-3- 

Few citizens object to the removal of trees, but cleareutti "<, will 
be 3 -" ' il lie's rury. I ,,}■■ 

wasteful It the public's eye. Ar economic a -i ) 
high lead roeathods of clearcuttl ob versus cat loaai"r, ve- 
logging lr, sensitive areas, versus the logins or sual] n lvate 

citizens is not only deficient , It Is absent. the 

value of old growth tln.ber 50 years fron; now as coir.nared to a ti 
14 Inches In dlaneter, It might be qulfe foolhardy to clearcut every 

il -g now. If It Is employment we seek, are altur-at've timber euttW 
practices liable to put more Deople to work? This document cries for 
a tter analysis. 

It seems to me most of the conflicts of timber land u °* occur 
on the same crou-d. Th= tourlts like the "ce-ery of the water, which 
1 where the fish live ana where the riparian zo-ee 9r e r-u-- 1 a* well 
as sensitive habitat. If meathods tcjextract logs from such ar-eas 
without substantially altering the forest could te contracted «rti- 
everyone cculd be accomadated. 
| This brings ire to a final point. I would like to see the 

33-6| alturr!atlves mapned out better. If they each have different acreaa 

|l wculd like to see what 1 -- grig wl re are the various protected 

areas and where Is the habitat to be protected by the differ' -b choices? 

The E1K needs to realize that in ad-ntlor I rcvldlne l s= 
for the mills they are also adjacert s for a lot of us a-d aor* 

are coming. .Vhlle I do not want tc see local mills shut, flow" thi« 1° 
no excuse to destroy America's legacy of natural beauty. 
For the shade of a tree. 



Richard Chasm 



111 



Response to comments in Letter 33 

33-1 Estimates of sport angl n t for the Umpqua 

Basin were provided by the (Oregon Dept. of Fish 1977 

and Hassleman 1979). Estimates of recreational use of public lands 
administered by the Roseburg District resulted from periodic 
at both developed and undeveloped sites. 

33-2 The North Umpqua River, although very high in sc . arxj a 

designated state of Oregon Scenic Area, does not fit the critei 
Class I scenery. It is categorized Class II (refer to DEIS, 
for description of classes). 

33-3 The economic effects of BLM-supplied fishing, hunting and outdoor 
recreation on local employment, personal earnings and public 1 
are evaluated in Chapters 2 and 3 of the EIS. The economic analysis 
is limited to these resource uses because they are the only uses for 
which reliable and regularly tabulated data exist. 

33-4 See response to comment 5-1. 

33-5 The economics of specific logging practices are considered in the 
design of each timber sale. 

33-6 M^>s are available for review at the Roseburg District Office for 
those alternatives derived through the land use planning process 
(Alts. 3, 4, 6, 8) as well as the new Preferred Alternative (Alt. 
9). 



43 




UMPQUA COMMUNITY COLLEGE 

THE COMMUNITY COLLEGE OF DOUGLAS COUNTY 



IS "BUD" HAKANSON 
President 



Posl Office Box 967 
Roseburg, Oregon 97470 0226 
Telephone 440 4600 



August 16, 1982 



District Manager 

BLM 

777 NW Garden Valley Blvd 

Roseburg, OR 97470 

Dear Sir: 

s recently come to my attention that you are proposing 
to adopt a plan which would require a number of acres of 
timber land to be immediately set aside to protect Spotted 
Owls. As I understand it, the Alternate 2 Plan would still 
aside 150,218 acres of old growth timberland. 

I: loss to understand why that would not suffice 
c )5 pairs of owls in our district. If you 
divide 150,218 acres by 55 pairs of owls, you 
2,731 acres per pair. If in fact that figure is cor. 
I would recommend that you adopt Alternate 2. 

This recommendation is made in light of our current 
economy, and the fact that it is subject to review later 

■ . 

We need to get Douglas County back on the road to economic 
recovery, and at the same time preserve the Spotted Owls! 

Sincerely, 



I. S. Hakanson 



Response to comments in Letter 43 

43-1 Alternative 2 would not set aside any old growth timber land with the 
exception of that for bald eagles and what may occur on non-commer- 
cial forest lands. There would, however, be ^proximately 150,000 
acres of mature and old growth forest remaining after one decade if 
Alternative 2 were selected and implemented, but the siz^ and 
distribution of owl habitat may be comprcmised by unconstrained 
timber management activities to the point where some habitat would no 
longer support spotted owls. 



President 



ISH 3 



SUN STUDS, INC. SUN VENEER DIV. 



44 



August 17, 1982 



Mr. James Hart, District Manager 

Roseburg District 

Bureau of Land Management 

777 N.W. Garden Valley Blvd. 

Roseburg, Oregon 974 70 

Dear Jim: 

This letter is in response to your request for comments con- 
cerning the D.E.I.S. for the Roseburg District Land Use and 
Timber Management Plan. 

Our general reaction to the Preferred Alternative is mixed. 
We are pleased to see a proposed increase in the allowable cut 
for the decade. We are concerned however at how this increase 
was justified. Most importantly we are disturbed at the very 
significant withdrawals from the commercial timber land base 
for the highly questionable purpose of dedicating old growth 
timber to spotted owls who may or may not need it. Further 
we are concerned about directing substantial management efforts 
toward this species when it is questionable as to what it's 
biological needs are and secondly whether or not the species 
really needs special protection in the first place. Because 
of these concerns which we feel are inadequately addressed 
in the D.E.I.S. we cannot support the proposed action. 

One of the common inadequacies we have found in practically 
all environmental impact statements is a tunnel vision con- 
centration on the impacts of forest management as they relate 
to the forest environment devoid of human influence. While 
this approach certainly caters to the views of the preserva- 
tionist camp, it does not address the concerns and needs of 
our community and our country. 

I This D.E.I.S. does address the concerns of the community to 
some extent. It does not however address in real terms the 
trade off of jobs and community stability versus preserving 
old growth timber for a population of owls. 

We are quickly learning in today's economy that our Nation 
has drifted too far away from the efficient production of 
basic goods and services that are necessary for human survival 
and betterment. Do you think for example that the unemployed, 
the poor people and the underfed people of this country and 
the world really are that concerned about spotted owls? 



Mr. J a me ■ 
August 17, 1982 
Page Two 

Our specific comments related to the D.E.I.S. fol j 

Environmental Consequences pages 4-6 

The author of this section obviously 

proposed action as black as pot. ,ts such as 

"changes in plant communities and habitat could 

some plant species" and "there would be significant long-' 

adverse impacts to some animal population certainly 

I designed to alarm the reader. Since this plan only covers a 
ten year planning period it would appear that these inflammatory 
statements are out of line. 

Criteria for Evaluating Alternatives page 14 

It would appear that some of the criteria identified are 
certainly more important to the selection of the preferred 
alternative than are others. Surely providing local economic 
stability must weigh more heavily in the decision making process 

I than for example providing for Research Natural Areas. I believe 
a grouping of these criteria by relative importance would 
provide a better idea to the public as to how a proposed action 
is chosen. It might even help the decision maker. 

Comparison of Impacts page 23 

In one short sentence on this page you have identified, probably 
by accident the key concerns of this Impact Statement. It 
reads "Two areas of major impacts are wildlife habitat and 
economic conditions". My first reaction is which is the most 
important, economics or wildlife habitat? Since the proposed 
action raised the land allocation for wildlife habitat and 
lowered the land allocation for timber management it is obvious 
that the concern for wildlife habitat was the greatest. I do 
not agree with this assessment, and neither do the vast majority 
of people who work for a living in this county. 

Environmental Consequences page 63-89 

(A) Introduction 

The concluding statement reads "A basic assumption of the 
analysis is that sufficient funding and personnel will be 
available for implementation of the final decision." For 
the sake of our economic well being we sincerely hope this 
assumption is valid. Judging by the experience of the 
Medford District and their newly adopted Timber Management 
Plan it is clearly a "high risk" that indeed funding won't 
be available and our proposed allowable cut will fall as 
monies for intensive management do not appear. Perhaps 
this gamble should be discussed in the section justifying 
increased allocation of land to wildlife habitat. 



Mr. James Hart 
August 17, 1982 
Page Three 

(B) Threatened or Endangered Plants page 71 

The concluding statement reads "Therefore, environmental 
analysis accomplished prior to any site specific action, 
would identify any threatened or endangered plant species 
known to be present on the site and appropriate measures 
to be taken." If this process is properly followed it is 
difficult to understand how "changes in plant communities 
44 _ 4 ^ nd habitat could eliminate some plants." {page 5) (Emphasis 
added) . Thus the elimination of some plants is not possible 
or likely. 

(C) Im pacts on Animals Terrestrial Vertebrates page 72 

"Lyon (1979) and Perry and Overly (1977) have shown that 
elk use is reduced within one-half mile of roads traversing 
elk habitat." I would suggest that you make these studies 
available for reading by the elk who frequently inhabit 
the old Hinsdale Ranch pastureland adjacent to Hwy. 38 
just east of Reedsport. These elk obviously do not know 
that their behavior is nonconforming to current standards 
set by Wildlife Biologists. 

(D) Threatened and Endangered Animals page 78-80 

In the final paragraph under Conclusions it reads in part 
"The cumulative effects on the northern spotted owl are 
difficult to predict as planning efforts,..., are just 
beginning." "However, if other agencies and BLM Districts 
do not provide for the recommended number then the species 
would certainly be in danger and be considered for Federal 
status regardless of the Roseburg decision." (Emphasis 
added) . 



Mr. James Hart 
August 17, 1982 
Page Four 

We recommend a complete rewriting be undertaken with the goal 
of eliminating the bias against timber management injected 
by wildlife worshippers. The only viable alternative in our 
view is Alternative #2 which should be identified as the 
proposed action in the Final Environmental Impact Statement. 

Sincerely, 

SUN STUDS, INC. 



Vice Preside: 
RER:vf 
cc : Douglas County Commissioners 




44-5 



We find this conclusion to be an incredible statement. In 
the first place if you cannot predict the cumulative effects 
on owl populations how can you say that the "species would 
certainly be in danger" ? Secondly this plan only covers 
a 10 year period at the end of which there will still be 
140,000 acres of old growth habitat on the District. Surely 
even the owls could still survive on only 140,000 acres. 

This entire section indicates a paranoid approach to wild- 
life management which we feel is completely uncalled for. 
Nothing presented in this section justifies a 20, 000 acre 
land allocation for the owls. 



Conclusion and Summary 

We do not support the proposed action chosen in the D.E.I.S. 
Giving away a significant commercial timber land base for 
the questionable purpose of saving a bunch of owls whose 
population dynamics are still up for debate in our opinion 
is a violation of public trust. Furthermore we feel the 
proposed action is in violation of the O&C Act of 1937. 



Response to comments in Letter 44. 



A 



47 
113 



Weyerhaeuser Company 



44-1 See response to cannon issue 4. 



P.O. Box 275 

Springfield. Oregon 97477 

AC 503 - 746 2511 



August 18, 1982 



44-2 The discussion on short-term impacts has been expanded in the FEIS, 
Chapter 3. EIS procedures require an analysis which goes beyond the 
10-year period to consider long-term impacts. 

44-3 Refer to revised Appendix A, O&C Forest Resources Policy. 

44-4 Present policy protects federally listed, proposed and candidate 

plant species but does not provide protection for other species that 
may be rare or rapidly declining in a single State (see revised 
Appendix A). Also, see response to comment 16-31. 

44-45 See response to common issue 1 and comments 11-8 and 43-1. 



Rose burg Di stri ct Manager 
Bureau of Land Management 
777 N.W. Garden Valley Blvd. 
Roseburg, Oregon 97470 

RE: 



We have reviewed and analyzed the Roseburg Timber 
Draft Environmental Impact Statement (DEIS) and 
following comments for your consideration in con 
the final DEIS. 



47-1 
47-2 
47-3| 



We support the 
to a few modi f 
harvesting tec 
Utili zing broa 
where appropri 
slopes under 3 
basi cal 1 y cons 
The BLM ref ore 
page 121 do se 
standards. We 
harvested acre 
intensive fore 
al 1 acres with 
have foun 3 i r 
over the rot at 



use of managemen 
i cat ions. In Alt 
hnique and age ; 
dcast burning as 
ate, and mechanic 
5%; as wel 1 as th 
istent with inten 
stati on managemen 
em to be out of 1 

also quest ion wh 
s would be schedu 
st management sys 
in a year of harv 
useful to ha* 
ion period of the 



t Alt ernat I ve #4 (PA) 
ernat i ve #4 , the pr i nc i pa 1 
he sit 
a primary source , 

1 site preparation I imi 
e reforesta t i on targi 
si ve forest management methods . 
t cost s , how* J on 

i ne with the accepted Li 
y only 91.77, ot the annual 
led for repl.int.ing sin. i 
terns call for rev- 
esting. Lastly, we 

!:' splay 

di strict . 



Alternative 4 provides for approximately 18,300 acres of 

buffers along third order and larger streams mana 

modified area control. Harvesting in this area would amount 

to an estimated 67„, of which only 11% would be by 

Harvest of stream buffers should be consistent with the Oregon 

Forest Practices Act. We do not support alternative #4 where 

it requires buffers in excess of FPA regulations. 



Bureau of Land Management 
August 18, 1982 
Page 2 



Bureau of Land Management 
August 18, 1982 
Page 3 



Alternative 4 calls for a 43,77 
sive timber product ion base (as 
situation). The majority of th 
wildlife habitat management tec 
reduction in the timber base, 
other forest uses, requires the 
"permanent forest production" 
It is inconsistent to restrict 
on federal land subject to that 

I mandate . We recommend that the 
cost/ bene fit analysis of its wi 
consider more scientific input 
Endangered Speci es Task Force i 
ment . 



9 -acre reduct ion in the inten- 
in contrast to the current 
t amount can be attributed to 

hniques. We do not support a 

The O&C Act, while promoting 
BLM to manage its lands for 

s a primary responsibi 1 i ty . 

harvest of old growth t imber 
legislated forest management 
BLM do some type of 

ldlife protection policies and 

than si mply the Oregon 

n terms of spotted owl manage- 



47-5 



In addition to support of a management al t ernat ive , we would 
1 ike to comment briefly on a few points of management phi los- 
ophy . On page 82 of the document we f ind , "most timber 
management pract i ces .. .create visible contrast in the land- 
scape. Assessing contrast for proposed activity can indicate 
the severity of impact and help identify mitigation measures 
to reduce the contrast and meet VRM class objectives for an 
area . " And 1 ater we find "all publ ic 1 ands would be 
managed in accordance with objectives to mitigate or in some 
cases avoid impact of management activities on scenic values." 
Nowhere do we find the rationale explaining why the BLM VRM 
objectives are appropriate or should be met at all. The 
proposal s for scenic area management are apparently based 
on t he as sump t ion that only the old growth stand is aesthet- 
LcalLy pi easing. In an area where timber is grown as a crop, 
serving as a basis for our 1 ivel lhood , we believe there is a 
need to redefine what is scenic . The broad mosaic of t imber- 
1 and ages from old growth to second growth to fresh clear cut 
should be viewed as natural and scenic . The current proposal s 
for visual resource protection subjugate forest management 
activity to a visual quality criterion which is loosely 
defined and not consistent with the mandate of the O&C Act. 

In regard to wildlife habitat management, throughout the 
document are found such statements as the following: 

Page 79: 'This long-term simplification (of stand struc- 
ture) and loss of diversity would be significant 
and adverse." 

Page 79: (Snag dependent wildlife), "Alternatives 6 and 7 

would support marginal populations while alterna- 
tive 8 would provide for adequate numbers . " 



Page 75: "...and 8 snag dwelling species would decline to 
bel ow BLM target 1 eve Is in the 1 ong term. " 

Page 73: "A situation exists as it is assumed that 

habitats are currently at caring ca pa city." 

Page 72 : "Once roads are closed to use, elk use incn 
to near normal level s . " 

Page 44: "Riparian zones are extremely important habitat 
because they are used to a greater extent bv a 
greater variety of species than any other 
habi tat ." 

Page 44 : "01 d growth forest s provide opt i mum h 
a variety of animal spec i > 



47-6 
47-71 



These statements imply a number of things 
is a definite set of standards the BLM has e 
del ineate good and bad levels of habitat mai 
of the statements made above, however, have 
the DEIS by actual direct documentation and, 
misleading. Secondly, the inference f 1 
the envi ronment is i nherent ly bad , is a bad 
example , when a field of weeds i s t urned i nt 
it is simplified but its habitat and food va 
increased . Last 1 y, most forest management a 
compati ble and beneficial to most wildlife s 
exceptions are an important issue but should 
bel ' e economic and forest management consi d 



First, that there 
-tied , whi ch 
ntenati 

ipported i n 

there t 

m p 1 i 1 i ■ 

as sump t ion. For 

e 1 d of corn, 
definitely 

The 
t be placed 

•ns . 



The DEIS recommends a cultural resource inventory on all acres 
involved in ground-disturbing activities. We do not support 
this act i on. federal law requires I ■ onl y 

i n areas likely to con tain a significant cul tui r that 

Lvities cease when such a site is discovered. To require 
surveys on all lands is a very ex pens i ve and Inef fecti ve 

Is of preserving cul tural resources . In any case, the 
cost of those surveys shoul d be borne by the BLM and not its 
licensees or contractors. 

The O&C Act places forest production in the dominant 

wi thin the scheme of the Bureau* s management of the O&C 1 ands . 

Further, it is agreed that the act does not mandate exclusive 

use but instead requires management for other intei 

wel 1 as t imber suppl y . The Inclusion of management 

for visual resources , exel us ive wi 1 dl i f e habitats and expanded 



||4 Bureau of Land Management 
August 18, 1982 
Page 4 



Response to conments tn ly 



ripari an zones , we feel , has gone beyond the management need 
for other forest uses and begins to significant ly erode the 
dominant role of timber production on O&C lands. 



Quincy ty. Pow. > 
Vice President 
Western Oregon Region 



47-1 See response to cannon issue 5. 

47-2 The acreage of initial planting ia equal to harvest area less roaded 
area. 

47-3 Harvest per decade in cubic foot volume would be constant for all 
decades for all alternatives until regulation is reached. 



47-4 See response to common issue 4. 

47-5 Nowhere in the VTW system is it said or implied that only an old 

growth stand is esthetically pleasing. Also, see revised Appendix A, 
O&C Forest Resources Policy, and response to comment 58-2. 

47-6 The following references are the basis for conclusions in the DEIS 
regarding each specific comment: 

Page 79 (simplification and diversity loss) 

Thonas (1979) states that although even-aged management will 
produce a mix of successional stages in the forest, the individual 
stands have a low vertical diversity because of the comparative 
simplicity of the stand structure. 



Page 79 (snag dependent wildlife) 



Page 44 (riparian zones) 



Thomas et al . (1979) state that the lower the population level 
managed for, the greater the risk of excluding a species from an 
area. They continue by saying that management below the 40 percent 
of potential population level may be too low to maintain 
self-sustaining populations. 



Thomas et al . cite several authors drawing the conclusion that 
wildlife use riparian zones disproportionately more than any other 
type of habitat. 

Page 44 (old growth optimum habitat) 



Page 75 (snag dwelling species decline) 



Refer to citation of Franklin et al., page 44 in DEIS. 



BLM wildlife program targets for cavity dwelling species seek to 
achieve maintenance of viable populations thought to be at or 
above the 40 percent potential population level. The analysis was 
based on this premise. 

Page 73 (carrying capacity) 

The concept expressed is one generally accepted by practicing 
wildlife biologists and used in this instance as a baseline in the 
absence of specific population numbers. 

Page 72 (roads and elk) 

Harcum (1975) found that elk use following closure of logging 
roads increased until it about equaled that on otherwise similar 
unroaded areas. 



47-7 The quantity and quality of the food and cover elements required by 
forest wildlife is a direct result of the condition and arrangement 
of the forest vegetation in space and time. In the long term, timber 
management regimes which employ low minimum harvest ages (50 years) 
and other intensive management techniques will lead to a forest 
ecosystem with a significantly lower wildlife carrying capacity. This 
decrease is a result of simplified vertical (within stand) and 
horizontal (between stand) diversity, v#iich is a product of the loss 
of stands 50 years and older. For species which depend upon stands in 
excess of 50 years to meet their life needs, the impact is both 
adverse and significant. 

47-8 Costs of cultural resource surveys related to the forest management 
program are borne by BUI. 



50 



August 19, 1982 



James Hart, District Manager 
August 19, 1982 
Page Two 



115 



50-1 



James Hart, District Manager 
777 N. w. Garden Valley Blvd. 
Roseburg, Oregon 97470 

Dear Jim: 

The purpose of this letter is to comment on the adequacy 
of the Roseburg Timber Management Environmental Impact State- 
ment (Draft) . 

Review of the Environmental Impact Statement (EIS) reveals 
serious deficiencies in the analysis of the Proposed Action and 
the seven other alternatives. Also, the employment of SIMIX as 
a forest simulation model to determine allowable cut levels will 
yield results that are fundamentally deficient in economic consid- 
erations. 

The National Environmental Policy Act requires that the EIS 
examine costs and benefits of the Proposed Action and other 
alternatives . The EIS goes to great lengths to identify the 
impacts to all aspects of the social and natural environment. 
However, the actual costs implicit in the Propsed Action are 
conspicuously missing. As an example, the Proposed Action contains 
allocations of over 30,000 acres for Spotted Owl habitat. Old 
Growth, and mature timber ecosystem preservation. After many 
somewhat complicated calculations , one can determine from the EIS 
that the setting aside of this productive forest land on 250 year 
rotations will cost the region $9.5 million per year in gross 
revenue and earnings and 287 jobs per year. Why isn't this signi- 
ficant cost explicitly stated? More importantly, how does the BLM 
justify this foregone revenue and employment? As a public agency 
charged with managing the O & C lands for the benefit of the local 
communities, the Proposed Action appears incongruent with your 
objectives. 

All of the alternatives presented in the EIS utilize SIMIX 
as a timber harvest simulator. SIMIX is a most inappropriate 
model for determining allowable cut levels on the Roseburg District. 
The vast majority of the timber on the Roseburg District is over 
mature. Managing over mature forest land under Sustained Yield- 
Even Flow model (SIMIX) is an unsuitable means of carrying out the 
legislative intent of the & C Act of 1937. The principle of 
Sustained Yield should be interpreted as an overall objective; 
to manage for continuous productive forest land. It should not be 
interpreted as a command to manage the O & C lands in an inefficient 
and wasteful manner. The scheduling of timber harvests under the 
Sustained Yield-Even Plow model has produced a history of chronic 
unemployment and economic stagnation in Western Oregon's timber 
dependent communities. The Proposed Action will perpetuate this 
situation needlessly. 



ef\ nl The utilization of SIMIX fails to portray the actual costs 
Ow ^| an d benefits of all alternatives, as required in the EIS process. 

According to the EIS (Appendix, page 127) "SIMIX is not designed 
to handle economic values or costs, 'and it does not seek out 
alternative schedules or strategies". Therefore, the Sustained 
Yield model (SIMIX) incorporates a zero interest rate into the 
harvest scheduling process. The outcome of this blatant disregard 
of economic criteria is evident in the forest simulation model's 
objectives. The purpose of SIMIX is to calculate the "highest 
sustainable allowable cut for each alternative", with a projected 
period of 400 years to "assure that the condition of no planned 
reduction in allowable cut can be met." Obviously, with a zero 
interest rate, the cost to the local population of a harvest 
schedule embodying a 400 year even flow level is insignificant. 
However, what is the actual cost in real terms of unnecessarily 
delaying liquidation of the BLM's over mature timber? 

It is hoped that these comments will lead to a better 
analysis and display of the costs and benefits of each of the 
alternatives and an examination of harvest scheduling options. 

Respectfully, 



.kr- 



K 



Ralph Saperstein 
1784 N. W. Estelle 
Roseburg, Oregon 97470 



Senator Bob Packwood 
Senator Mark Hatfield 
Representative Jim Weaver 
Robert Burford 



58 



Response to conments in Letter 50 



50-1 See response to common issue 4. 



W LUMBER CO. 



P. O. BOX 108 



ROSEBURG, OREGON 97470 PHONE (5031 679-874 



50-2 The comment refers not so much to SIMIX as to the policy on 
non-declining even-flow constraint. SIMIX does not: 

- inherently handle costs and benefits 

- incorporate economic analysis or optimization 

SIMIX is generally recognized as a valid model given an even-flow 
constraint (refer to DEIS, Appendix C, page 127). The allowable cut 
determination is based on a nondeclining harvest level over time (See 
OfcC Forest Resources Policy, Appendix A). 



August 18, 1982 



Mr . James E. Hart 
Roseburg District Manager 
Bureau of Land Managemen t 
777 NW Garden Valley Blvd. 
Roseburg, OR 97470 

Dear Mr. Hart: 

This letter is in response to your request for input on the draft 
Timber Management Environmental Impact Statement lor the Roseburg 
sustained yield unit. 

Roseburg Lumber Co. is highly dependent upon the Ros< 

for its timber supply. We operate plants at li\ raphic 

locations in Douglas County, which normally employ approxin 
people. These facilities all draw wood from the Rob<! 

In that our operations are extremely dependent on the federal govern- 
ment for thier timber supply, any change in the allowable cut ha 
tremendous impact on our future. 

Roseburg Lumber also has a close historical relationship with tl 
lands, in that the bulk of our industrial timbe: 

with the BLM patchwork ownership. Because of this situation, Wi 
very much concerned about the land use and silvi cultural recommend 
contained in the various alternatives. Such 



a direct and long te 
administered. 



Such programs will 
impact on the manner in which our lanci- 



rongly recommend the selection ol 
is based on the iol lowing reasons: 






In Douglas County , the wood products indus 

provides jobs for more than 90% of the Coum 

manufacturing employment . Becau 

ship with si ' trade employment, anj 

in the base wood industry employment has an amp 

affect on the whole company. 

The flow of O i C funds to various local government 
agencies is critical in the maintenance and growth 
of many key government servj 



116 



E. Hart 



i 18, 1982 



James E. Hart 



Augunl 18, 1982 



3. Under the O k C 137, the ro nues 
from ,i ion both 
from a congressional mandate, and in support of 
local SOG i : , ruber 
production as the dominant use on forest lands 
admin Bureau of Land Management. The 
law elling, cutting and 
regrowing <>i timbei lominant use on 

mi the objective of main- 
ting a stable economic base for local dependent 
communi tie 

4. This stable revenue base is certainly not the cs 
today in the local Douglas County economy. Industry 
and communities throughout the Douglas County area are 
reeling as the result ol the collapse of the national 
wood products market. Although this is hopefully a 
short term problem, a stable wood supply is critical 
for any near term recovery. 

5. Local industry is going through a transition, both 
in terms of technology and wood supply. In the next 
20 years, there will be a supply gap between the old 
growth and second growth timber stands as indicated 
Ln the Beu , which was part of the Forestry 
Program for Oregon (published in 1977). During this 
period, the need for a stable and re 1 i able timber 
supply will be greater, in that the economy will be 
quite f ragi le. 

6. Although Alternative #2 "emphasizes timber production", 
this management program more than meets the standards 
that have been establ ished by various agencies relative 
to the protection of the watershed, wildlife, and other 
environmental and multiple use resource values. 

During the decade of the 1970s, there was a period of experimentation, 
both in terms of environmental and forestry management concepts . 
Because of the avai lability of the forest resource, the philosophy 
has been to hold volume in reserve in order to ensure that non-timber 
resources were protected. As a result, the short term economic 
productivity of these lands was sacni 

Given the present economic situation, the clear mandate contained 
in the & C Act, and the broader base of expertise that has been 
developed over the last decade, it is now time for these lands to 
contribute their full capacity to the needs of our community. 
alternative 02 presents the proper compromise in meeting these various 
object i \ 



1 . 

58 1 



58-2 



58-3 



We shai iti ting 

a potentially uni- 
ts a trade off i 
in thi i < st land base. If the avail- 

ability of these fund 
probable in 

I supply on an already str.i my would be 

catastrophic . 

There void in the dr;. 

to the goal of proper coordination ob »ith 

with other landowners and agencies (pages 26-27). There 

is considerable discussion and analysis of management 

techniques r< I directives and guld< 

establ lshed by federal and state agencies . But there 

is no consideration of the tremendous interaction 

between the private/industrial landowner and the 

Bureau of Land Management. 

Given the patchwork nature of the k C land own* 
the manner in which these lands are managed has a 
significant impact on the adjacent landowner. This 
interaction ef f ects land use , road access , and general 
forest management. Although the bulk of Roseburg 
Lumber Co. 's industrial forest lands intermix almost 
in their entirety with the Bureau of Land Manat 
ownership, at no time were we contacted relative to 
the Impact of this plan on our operations, or the 
potential impact on our management procedures on the 
BLM ownership. 

This lack of coordination is specifically illustrated 
in certain land use catagorles. On page 83, there 
is a list of areas that qualify for visual resource 
management (VRM), and designated with high sensitivity 
levels. In this category, logging and forest manage- 
ment procedures are restricted in order to preserve 
certain esthetic values. 



In viewing the plan from a detailed standpoint, 
the following points: 



I would like to make 



For example, one area 
Reservoir. When this 
by the County as a wa 
understanding be1 
the County . Existing 
conducted as long as 
Oregon Forest Practic 
degradation to the wa 
without any prior con 
or County Planning st 
additional zoning ove 
timberland on the & 
precedent for restric 
of lands intermixed w 



so designated is the Berry Creek 
area was originally proposed 
tershed, there was a very clear 
small landowners, industry and 
forestry practices would be 
they were consistent with the 
es Act, and did not result in 
tershed. Suddenly, the BLM, 
sultation to adjacent landowners 
aff, has in affect proposed an 
rlay. In restricting commercial 

C, you have also set the 
tion on the operational capaci ty 
ith these holdings. A similar 



James E. Hart 



August 18, 1982 



rQ olsituation is true on at least 30% of the proposed 
OO v|areas contained on page 83. I would strongly 
recommend that this superficial assignment of 
management restrictions on lands intermixed with 
commercial timberlands be reviewed. Roseburg Lumber 
would be happy to provide detailed input in such 
a process. 

I hope, that in developing the final draft statement, the agency 
will use common sense in establishing the appropriate balance 
between various resource uses. In that the economic problems of 
the Douglas County area are so obvious and so critical, the selection 
of Alternative #2 represents the one sound approach in meeting the 
needs of both the environment and the community. 

Sincerely , 

ROSEBURG LUMBER CO. 



Response to comments in Letter 58. 

58-1 See response to common issue 2. 

58-2 Of the visual resource areas listed on page 83 of the DEIS, forest 

management activity restrictions are limited to BLM recreation areas 
and State of Oregon designated scenic areas (segments of North Umpqua 
Highway 138, Highway 42, 227 and Interstate 5)- Otherwise, mitigating 
measures and project design features as described in the DEIS 
provide for scenic values in such areas as Berry Creek Reservoir. 



Allyn C. Ford 



58-3 Management of intermingled private lands is controlled by State Laws 
and local land use plans. Refer to DEIS, Chapter 1, pages 27-29. 



BLM's preferred land use alternative and other alternatives 
considered in the land use planning process were reviewed by the 
Douglas County Planning Department. Tne Preferred Alternative is 
believed to be consistent with Douglas County's Comprehensive Plan. 
BLM visual management practices are not intended to set any precedent 
for the management of intermingled private lands. Also, see response 
to comment 4-4. 



68 



DOUGLAS TIMBER OPERATORS 

Suite 222, Pacific Building 

Roseburg, Oregon 97470 



August 18, 1982 



117 

land to constrained timber production. Th ; 

Owl habitat, old growth and ecosystem preservation thai 

on artificially long (250 years) rotal 

tion of the O & C grant land ront to th- 

munities adjacent 



Mr. James Hart, District Manager 
Bureau of Land Management 
777 NW Garden Valley Blvd. 
Roseburg , Oregon 974 70 

Dear Jim: 

The following comments pertaining to the Roseburg Timber Managem-i;' 

Environmental Impact Statement (Draft) are submitted on be hi 

the Douglas Timber Operators . As an association representing local 

t product manufacturers, loggers and retailers, with subs' 
tial dependence on public timber supplies, our interest in planning 
Cor the future management of local forest lands is acute. Over 
l ? , 000 workers in Douglas , Coos and Lane Counties are norma lly em- 
ployed by our members . 

As we are all aware, the nation is experiencing the severist reces- 
sion in decades. Local timber supply will have a profound effect on 
the forest industry' s ability to provide prosperity and stability for 
the area. Therefore, BLM planning decisions can hold the key to local 
companies ' likelihood of surviving the current recession and thriving 
once the economy turns around . 

The Proposed Action, as described in the DEIS, has some serious short 
comings. The PA designates 52,000 acres of prime commercial timber 



68-1 



In light of the nev. >m the Washington, D-C. 

garding the selling aside of produi 

timber uses, revision of the Proposed Actioi 

cision to remove 52,000 acres from the Intel 

base was derived from i 

ledge. In addition, in 198J the Oregon State Lei 

Memorial No. 1 . In this resolution thi 

"make cor tain every possible effort is rr.^it t_ ^ p.- ..-.ser ve the in tens l ■■■■:- 

management land base for timber production purposes" . 

This statewide emphasis on preserving the land ba.-^e 1 
• ■ t Land is not new. The Oregon Board of Forest .i 
state position in its Fores try Plan -or Oregon. A ba 

the progran is "to maintain the maximum potc; 
base consistent with other resou- 
quality". The Proposed Act ion is l no 

Consequent ly , reductions of the managed timber land b-i 
conflict with policy and objectives from the BLM headqu 
ington, D.C., the Oregon State Legislature, the Oregon Board o* 
local governments and the forest industry of Southwestern Oregon . 



Another facet of the Proposed Action which deserves closer scrutiny 
in the decision process is the heavy reliance on intensive management 
to maintain allowable harvest levels. The Proposed Action will require 
an increase in funding of approximately 42% to meet intensive manage- 
ment object ives. While this increase may be feasible for the long-run, 
it is unlikely for the short -run, considering current reduced stumpage 
values and congressional unwillingness to provide supplemental appro- 
priations. Your ability to carry out the proposed course of action may 
be in serious jeopardy. Any reduction or elimination of cultural treat- 
ments will in turn force a reduction in the al lowable harvest. A similar 
situation in the Medford BLM District, where harvests had to be reduced 
over 20MM, demonstrates the reality of our concern. The most likely 
effect of the Proposed Action with its reduced land base and dependence 
on intensive management would be to meet the harvest objectives . 

Alternative 2 offers a much more viable and appropriate plan for managing 
the Roseburg District. Alternative 2 provides for over 360,000 acres in 
the Intensive Timber Production Base which is over 27, 000 acres more than 
the Proposed Action. The addi tional increase in annual sustained yield 
harvest of 18 million board feet will yield additional public revenues 
and worker earnings. In addi tion, Alternative 2 would produce over 300 
jobs more than the Proposed Action. 

The benefits of Alternative 2 are achieved without sacrificing non- 
timber resources and uses on the Roseburg District. Stream protection, 
visual quality and wildlife habitat is enhanced with an al location of 
24,786 acres. Alternative 2 will more than double the area designated 
for recreation with respect to current conditions. Most important ly. 



at the end of 10 years, over 140,000 acres of m« < : will 

still be available for reclassification. This factor the op- 

tion to provide adequate protection for the Spotted Owl and old growth 
ecosystems, should continuing research deem permanent land alJor ■ 
necessary . 

In order to provide scientifically sound analys : . 

the DEIS, DTO has retained the services of two independent con;- i 

firms. Dr. Robert Vincent has 

draft. Ma. c on Bruce & Girard, Inc. has reviewed the ecom 

in the DEIS. The results of the] 

considered as part of DTO's formal input t< 

Based on our review and the rep 
that in the BLM to conn: 

and local objectives t he Proposed Action should bo aband 
and Alternative 2 adopted. The BLM will ha\ 
in your efforts to appropriately revise the Proposed Action. 

Si net : 
DOUG; 



fi^jt^CL^T' 



Lynn Herbert 
President 



118 



AN ANALYSIS AND DISCUSSION OF THE WILDLIFE-FOREST ASPECTS 

OF THE ROSEBURG TIMBER MANAGEMENT DRAFT 

ENVIRONMENTAL IMPACT STATEMENT 



Page 

INTRODUCTION 2 

ALLOCATION OF MATURE AND OLD-GROWTH ACRES FOR WILDLIFE .... k 

ELK AND ROAD SYSTEMS 15 

INTENSIVE FOREST MANAGEMENT AND WILDLIFE 18 

RIPARIAN AREA MANAGEMENT AND FISHERIES 23 

CONCLUSIONS 25 

LITERATURE CITED 27 



prepared for 
DOUGLAS TIMBERS OPERATORS 



Robert E. Vincent, Consultant 
August, 1982 



I INTRODUCTION 



The Roseburg Timber Management Draft Environmental Impact Statement is a major 
improvement over previously written EISs. Issues have been addressed, data 
presented, and alternatives analyzed in a comprehensive manner. The Timber 
Production Base is particularly important for, although BLM assumes funding 
will always be available for intensive management, this may not be the situation. 

By far the largest acreage in the SYUs is withdrawn from the intensive Timber 
Production Base for wildlife habitat. A Constrained Timber Production Base 
through Modified Area Control harvest has merit over no harvest; nevertheless, 
acres allocated for constrained production should be examined carefully and 
constrained harvest applied sparingly. This analysis focuses upon those wildlife- 
land allocations that most reduce the Intensive Timber Production Base. 

Subject areas emphasized in this discussion are (1) old-growth forests and 
spotted owls, elk, and corridors; (2) elk and road systems; (3) intensive 
forest management and wildlife; and (4) riparian areas. Generally, the analysis 
shows that, for this planning cycle, allocation of old-growth forest need 
not be carried out because a more-accurate, meaningful allocation can be made 
later with greater information and no Individual resource will decline to 
any extent in the meantime. Also, literature and common knowledge strongly 
suggest that road impact upon elk use of habitat may be overemphasized. Broad 
condemnation of the impact of intensive forest management on wildlife is not 
justified, and the proposed riparian area management will adequately protect 
and enhance the many uses of streamside areas. 



hatchery fish have a role in the fishery, for listing MFP Withdrawals by use, 
and for preparing a table of nonoverlapping resource allocation of forest 
land. 

One major weakness seems to be conclusion forming contrary to the supporting 
and stated information. 



The BLM is to be commended for proposing the concept of Area Control Harvest, 
for considering a 250-year-harvest age of riparian and wildlife old-growth 
blocks, for managing the Tyee Area with special consideration for elk, for 
realizing the possible wildlife use of non-forest lands, for recognizing that 
- 2 - 



119 



II ALLOCATION OF MATURE AND OLD-GROWTH ACRES FOR WILDLIFE 



The Roseburg BLM Sustained Yield Units (SYUs) contain approximately 423,896 
acres in total. As an example of how the intensive forest management base 
is computed, Alternative 2 and Alternative 4 (Proposed Action) are examined. 
Land allocated for Planned Timber Harvest under Alternatives 2 and 4 is reached 
by designating acres for either no harvest or for constrained harvest. 



Acreage Allocation 



Alternative 2 Alternative 4 



Total Acres 

No Planned Timber Harvest 

Physical Land Characteristi 
MFP Withdrawals 
Planned Timber Harvest 
Constrained Base 
VRM 

Wildlife 
Intensive Base 



423,896 


423,896 


38,530 


38,530 


32,530 


32,826 


5,704 


5,704 


385,366 


385,366 


24,786 


52,047 


3,682 


2,646 


21,104 


49,401 


360,580 


333,319 



Thus, the difference of 27,261 acres between the Intensive Base Alternative 2 
and the Proposed Action is the acreage allocated for spotted owls, old-growth 
blocks, and 80-acre blocks, in other words, the acreage of mature and old- 
growth forest for spotted owls and for old-growth corridors. VRM, bald eagle, 
osprey, raptor, and riparian acreage allotments are all the same between the 
two alternatives. 

These constrained harvest acres of old-growth forest for wildlife, even with 
limited harvest under Modified Area Control, remove 18 MM bd. ft. from the 
annual timber harvest. Therefore, these 27,000 acres that grow 18 MM bd. 
ft. are significant and worthy of evaluation as to why they are placed in 
the Constrained Harvest Base. To illustrate the comparative magnitude of 
impact of 18 MM bd. ft. on local employment and earnings in Douglas County, 



18 MM bd. ft. 
Timber Harvest 


All Other 
Resource Occupations 


232 
$ 3,072,600 


99 
$ 567,000 



note the following: 



Persons Employed 

Personal Income 

Three wildlife resource allocations comprise nearly all of the Constrained 

Base: (1) spotted owl habitat, (2) old-growth blocks that are overlapping 

or joint-use for all except 1,757 acres, and (3) 80-acre blocks that are nearly 

all single-use designation (9,415 acres, single-use; 1,167, overlapping-use) . 

A. Existing Situation 

In contrast to some BLM Districts, the Roseburg District has large acreage 
in mature and in old-growth stands. Also, the District has a comparatively 
large spotted owl population. High amounts of these three permit flexibility 
in the planning process. 

1. Mature Forest. The SYUs contain 79,800 acres (202) in the 116-to- 
195-year-habitat age class, while all lands contain 121,500 acres (92) of 
mature forest. 

2. Old-Growth Forest. The SYUs contain 110,900 acres (27%) in the 196+ 
-year-habitat age class, while all lands contain 234,100 acres (162) of old- 
growth forest. Accordingly, mature and old-growth forest are not a scarce 
habitat-age class but total 190,700 acres or 47% of the Roseburg District. 

3. Spotted Owl Populations. Current census effort has found 55 habitat 
units that each support a pair of owls, plus found 30 additional locations 

in the SYUs where spotted owls have been found occasionally. In addition, 
63 pair of owls have been recorded on other ownership within the planning 
area. A total of 148 pair of spotted owls are known thus far to occupy habitat 
within the EIS area. Of the known 55 habitat units in the SYUs, only 4 were 
estimated to be in poor (less than 150 acres old growth) condition. Sixteen 
of the occupied habitat units have less than 300 acres of old-growth forest. 
Hence, 30% of the known locations supporting a pair of spotted owls in the 
SYUs are doing so in a habitat unit smaller than 300 acres of old-growth forest. 



68-2 



The permanency of spotted owls in small habitat units is unknown, but they 
are there and they have been counted with regularity. 

B. Old-Growth Forest and Spotted Owl 

Present status of the spotted owl population would have to be considered good 

in the SYUs. The Proposed Action is to protect habitat fully for 18 pair 

of owls, habitat that consists of a 300-acre, old-growth core plus an additional 

900 acres with at least one-half older than 30 years. Through the 10th decade, 

this action would maintain the prescribed pairs of owls. The relationship 

between spotted owls and acres of old-growth forest is unclear. According 

to Table 1-5 (DEIS), if 1,000 acres were a minimum-habitat requirement, the 

spotted owl would not exist to the 10th decade under Alternatives 3 and 4, 

notwithstanding that 31,800 of old-growth forest would be extant. Under Alternative 

7, no owls would exist by the 10th decade even with 70,000 acres of old-growth 

forest, whereas under Alternative 6 with 68,100 acres, 24 pair would be maintained. 

These relationships are inconsistent. 



68 3 



No pro ject 1 



are given for spotted owl populations at the end of the first 



decade so extrapolation must be done from the acres of old-growth habitat. 
The existing condition has a known habitat unit for each 2J300 acres of potential 
habitat. Consequently, at the end of the first decade, all alternatives except 
5 could be expected to maintain a minumum of approximately 35 pair. 

Data on habitat requirements of spotted owl are limited and incomplete. Current 
available data are solely from the research of one individual. Confusion 
also exists between the original Oregon Endangered Species Task Force management 
recommendations and the proposed revision of the Oregon Interagency Spotted 
Owl Management Plan. Although the latter is only a proposal, not an accepted 
or adopted revision, even as a proposal the revision was to maintain the option 
of the additional acreage of old-growth forests for a 5-year period only. 
68 _ 4|' Yet » this unadopted proposal is repeated and used several times in the DEIS. 

Lack of data become awkward for the authors of the DEIS for it appears necessary 
to inject frequent "weasel" words because definitive data are absent. A manage- 
ment decision that impacts millions of board feet of timber harvest annually. 



68 5 



needs to be based on facts, not supposition. Phrases and words as "these 
may be . . ."(p. 47), "in the opinion of the BLM district biologist . . ."(p. 47), 
"applying extremely rough projections . . ."(p. 72), "assuming that these recommendations 
. . ."(p. 78), "based on the assumption that . . ."(p. 79), "assuming," "indicates," 
"may be" (p. 80), and "the cumulative effects on the northern spotted owl are 
difficult to predict as planning efforts by land management agencies are just 
beginning . . ."(p. 80) express indecision. In addition, "no action would 
be taken until habitat management plans are completed . . ."(p. 79) obviously 
show habitat management plans have not been formulated for wildlife areas. 

Given the necessity of using these many indefinite words, given the statement 
that cumulative impacts on the owl are difficult to assess, and given the 
absence of wildlife-habitat management plans, the logical conclusion is that 
BLM needs additional planning time so that a decision of this magnitude is 
not being based on guesses and assumptions. 

The same indefinite phraseology is used to disguise lack of hard data on older 
forest habitat: "the functioning of the old growth forest as a system, however, 
has not yet been studied in depth . . ."(p. 42), and "there Is no definitive 
description of the functioning of the old growth system and its importance 
to long-range timber production"(p. 71) . Again, the need to guess is shown 
by "habitat structure for all lands . . . cannot be accurately calculated"(p.44) . 
Confusion of the role and amount of old-growth forests is further compounded 
by the sentence on p. 71, "All alternatives except Alternatives 1, 2 and 5 
would provide an adequate representation of the original old growth systems." 
Yet after 10 years, the timeframe of this Timber Management Plan, there is 
a IX difference in the acres of old-growth forest under Alternative 2 and 
Alternative 3. In this situation where admittedly the function and importance 
of old-growth systems are not well known nor the amount accurately calculated, 
it is inconceivable that precise prediction could be made that Alternative 
2 would not provide adequate representation while Alternative 3 with only 
IX more old-growth habitat would provide adequate representation. 

Replacement of younger forest with older forest is a basic premise of BLM 
planning as shown by Alternative 8, 80-acre blocks of mature timber, the corridor 



120 



Led Area Control. Or BLM cannot squ. 

the concept In their own thinking that old-growth forest is irreplaceable. 
Irretrievably lost does not app I rowth forest. Thifl latter concept 

is expressed tacitly by "old growth habitat that would be irretrievably lost 
as long as those acres are managed im timber production . . ."(p. 72). 

Certainly the implied idea is that whenever intensive timber management vera 
stopped, old-growth habitat would not be irretrievably lost but would be reformed 
as a natural consequence of succession and community development as expressed 
on p. hi and p. 44. Moreover, if as assumed by BLM (p. 73) that habitats are 
currently at carrying capacity, these new old-growth stands will support populations 
of those species that prefer old-growth forests. 

Thus to sum up, the best planning action for the spotted owl may well be to 
take no action during this planning period for the following reasons: 

(1) At the end of the planning period covered by this DEIS, over 70,000 
acres of old-growth forest will remain in the SYUs under all alternatives 
except Alternative 5. 

(2) Spotted owl numbers are comparatively high. 

(3) Confusion exists over minimum habitat requirements of spotted owls. 

(4) The relationship between owl habitat and older forest is unclear. 

(5) At the end of the planning period an adequate number of owls will 
remain even without special allocation at this time. 

(6) Lack of data on owls and their habitat necessitates the frequent 
use of non-specific phrases. 

(7) Habitat management plans have not been completed for SOMAs. 

(8) The function and role of the old-growth system is unknown. 

(9) Old-growth forest is replaceable and is a renewable resource 

The spotted owl was classified as threatened by the then Oregon Department 
of Wildlife on January 10, 1975, and no species have been added to or removed 
from this classification since that date. At this time, other states and 
provinces have not given the spotted owl special designation. British Columbia, 
Washington, or California do not have specific management considerations for 
the spotted owl, and owls have the same legal status and protection as all 
other native nongame birds in these three states. The owl is not listed nor 



I 



has it been proposed for listing under the Federal Endangered Species Act. 
"The species (spotted owl) situation does not meet the Endangered Species 
Act of 1973 definitions of either Threatened or Endangered" (U. S . Fish and 
Wildlife Service 1982 p. 24). 

C. Old-Growth Forest and Elk 

Elk are unevenly distributed throughout the SYUs with a concentration in the 
Tyee Area of the Drain Unit. The elk population of 660 provides an average 
annual harvest on BLM land of 54 elk and an annual expenditure of 2,738 hunter 
days (Roseburg District PAA) . Over one-half of the harvest is from the Drain 
Resource Area. As a result, elk hunting la a minor resource use in the SYUs 
and needs to be viewed in prospective with dollars and people involved in 
other resource uses. 

The relationship between elk and old-growth forest is unclear and ill-defined. 

If available, elk may well use old-growth stands; on the other hand, the requirement 

of old-growth forests for elk survival is probably mainly a "smoke-screen." 

To many, common knowledge examples exist of elk herds thriving in almost total 

absence of old-growth forests: Tillamook Burn, Clatsop Plains, Millicoma 

Tree Farm, etc. The real issue of elk habitat is obscured by the use of a 

large, popular big-game animal as a surrogate for old-growth forest protectionism. 

On p. 46, 73, and 74 (DEIS) mature and old-growth forests are designated as 
necessary components of elk habitat. The essential ingredient provided by 
these habitat types Is survival cover that is defined in the glossary In relation 
to severe winter storms of heavy snow fall. Structure of mature and old- 
growth forest provide thermal cover and limited food in close proximity. In 
contrast to the glossary definition (p. 74), extreme summer temperatures are 
considered part of survival cover. 



Climate in the SYUs is temperature marine with warm summers and mild, wet 
winters. Precipitation is mostly rain and "snow is generally short-lived"(p.32) . 
Under such mild weather conditions, "extremely severe winter and summer weather 
. . ."(DEIS p. 74) would occur rarely. Critical evaluation is essential If 
resource allocation for extreme weather of a habitat type is needed so 



68-7 



seldom. An analogy could be made with an individual planting 100 acres in 
wheat each year just in case the United States should have a famine. Each 
year taxes are paid; seed is purchased; land is plowed and cultivated; the 
crop is sprayed, fertilized, and finally combined only to be discarded because 
the famine did not occur. Is survival cover worth the "just In case" cost? 

The definition of survival cover for weather extremes is not precise. In 
the DEIS, mature and old-growth stands are always both used as meeting the 
structural requirements. Referring to 80-acre blocks of 120+ to 200+ year 
old stands, "These stands will also provide the stand structure (canopy closure 
and food resources) necessary to meet the survival cover needs of deer and 
elk during severe winter weather" (MFP-NU-WL p. 11). So apparently mature forest 
(116-195 years) will meet survival needs and old-growth forest is not necessary. 
In addition, RAA-NU-WL (p. 18) stated about severe winter weather cover, "Stands 
aged 50 to 200 years old will fulfill these needs efficiently, though older 
stands, if present, are preferred." On p. 103 in the same document, the following 
statement is written, "Although younger stands (80+ years) will provide summer 
thermal cover needs for deer and elk, the stands aged 200+ years old are needed 
to totally fulfill the animals' need for cover and emergency forage during 
periods of severe cold, wet or snowy weather conditions." This statement 
by BLM says (1) that 80+ year-old stands will meet summer thermal cover needs, 
(2) that cold and wet are also a reason for survival cover, and (3) that the 
objective is to totally fulfill all needs of the animals. Whether the stands 
are 50+ or 80+ years old, these are far younger than old-growth stands. Also, 
for an animal whose supposedly optimum habitat is Coast Range rainforest, 
it is difficult to imagine rain being a problem. "Elk appeared indifferent 
to average coast range winter weather . . ." (deCalesta and Witmer 1981 p. 38) 
and furthermore elk used cover less on adverse winter days than on mild winter 
days. Mandel and Kitcjien (1979) also saw elk often bedding or standing in 
the open during heavy rain. To totally fulfill animals' habitat requirements 
for all emergencies is impossible. The possibility of a more severe weather 
event, a larger forest fire, a greater volcanic erruption, a new disease outbreak, 
a more efficient competitor, a higher flood, etc., is always present. Habitat 
needs for these rare contingencies cannot be totally met even with unrestricted 
cost and unrestricted resource allocation. 



I Thus, survival cover (summer and/or winter?) can be met by stands 50, 80, 
120, or 100+ years of age depending upon definition and criteria used in the 
DEIS. This highly specialized survival cover could be a possible essential 
habitat element only under rarely occurring climatic events. Elk are not 
hindered enough to move by snow depths less than 18 to 24 inches (Beall 1974, 
Leege and Hickey 1977, Martinka 1976, Schoen 1977). Snow depths of this or 
greater magnitude are rare and short-lived for southwestern Oregon. 

Currently, 60% of Tyee Area is in 80-year or older forest habitat (DEIS p. 45). 
Actually, whether elk must have or whether elk can do well without older forest 
becomes a moot question with so much mature and old-growth forest. This is 
recognized by BLM for "no impacts (on elk) are expected in the short term 
. . ."(DEIS p. 79). Short term is defined as 10 years (DEIS p. 64). In addition. 
Table 3-11 indicates that no change in elk population will occur in the second 
decade either. Under any of the alternatives, elk habitat will not be changed 
enough to impact elk. populations for at least 20 years. 

In the Tyee "none of the lands scheduled for long rotation under modified 
area control are located in this area. . . ."(DEIS p. 74). Then by comparing 
Table 3-11 and Table 3-9, one Interprets that mature and old-growth forest 
can be reduced by approximately 60% without changing the elk population. 

Further support comes from Schoen (1977), who found that an elk herd in Western 
Washington avoided old-growth stands in winter; from Harshman and Jubber (1980), 
who found that elk survive during periods of heavy snowfall in the Western 
Oregon Cascades in 80+ year-old stands; and from deCalesta and Witmer (1980), 
who are cited as proof of requirement of old-growth forest. In fact of the 
latter, the research year had only a trace of snow making meaningless a conclusion 
that old-growth stands were essential to provide thermal cover and forage 
under extremely heavy snow conditions. 

Summer temperature relationships between elk and vegetation are complex, much 
more so than air temperatures as measured by deCalesta and Witmer (1981) in 
just the two temperature extremes of old-growth stands and recent clearcuts. 
Elk, by their behavior, adapt to temperature (Beall 1976). They move less 
in midday (deCalesta and Witmer 1981 p. 21, 31; Schoen 1977 p. 132) with a dally 



121 



activity of feeding morning and evening and retreating to cover in midday 
(deCalesta and Witmer 1981 p. 37). Thus, high-midday air temperature in recent 
clearcuts really have minor impact on elk. Not only may cooler mid- summer 
air temperatures be found in old-growth stands but in younger-growth stands 
as well. Second-growth stands may significantly moderate weather conditions 
with the dense canopy reflecting solar radiation, thereby creating a micro- 
climate more favorable for elk (deCalesta and Witmer 1981 p. 32, 35). Elk do 
respond to air temperature. Respond is the key. Elk are intelligent animals 
found over a wide range of topographic and climatic conditions. Normally, 
they are not found at midday in midsummer in the midst of a recent clearcut 
where air timperatures are 100-plus degrees F. (Pedersen 1976). On the contrary, 
if old-growth stands, dense, young-growth stands, hardwood stands, or north 
slopes are available, elk will be in the shade. The shade need not necessarily 
be provided by old-growth stands. 

As a result of the large acreage of mature and old-growth forest in the SYUs 
and of the need to define habitat requirements more precisely, no immediacy 
exists to allocate resources for elk survival cover at this time. Special 
timber harvest regulations proposed for the Tyee Area such as smaller clearcuts, 
distance to cover, cover width, road closure, etc., will enhance populations 
in this significant elk area. 

In conclusion, enlightenment is provided by the importance of the Tioga Management 
Unit of ODFW to Roosevelt elk kill in Oregon. It is a "premier area as it 
contributes an average of 51.5% of the Roosevelt elk kill, . . ."(in Oregon) 
(RAA-DL-WL p. 21). This Unit also provides over half of the elk harvest in 
the Dillard Resource Area. The same paragraph continues, "It should be noted 
however that the bulk of the recorded kill came from lands owned by the Weyerhauser 
Company and not those (BLM lands) within the planning unit." These private 
forest lands that grew most of the elk were not mature or old-growth forests 
but lands that had been clearcut over the past 25 years. 

D. Mature and Old-Growth Forest Corridors 



land allocated for corridors is commendable and has been partially successful. 
The basic question is the concept of corridors. True, the habitat blocks 
are "located in loosely arranged corridors . . ."(DEIS p. 124) or "generally 
located within a corridor . . ."(DEIS p. 15). Still, 1,757 acres of old-growth 
forest and 9,415 acres of mature forest are single-use allocations solely 
for corridors. Comparing location of large blocks of old-growth forest with 
location of spotted owl areas gives the impression that some old-growth areas 
were chosen not as the best owl habitat but to fill corridor gaps. 

Large old-growth blocks (approximately 600 acres each) are cited (MFP-NU- 
WL p. 19) as a requirement for spotted owl, fisher, marten, and possibly cougar. 
The fisher population level is at or near zero at the present time (RAA-DL- 
Wl p. 41) and may have already passed from existence (RAA-DL-WL p. 95). Both 
the marten (RAA-DL-WL p. 41) and cougar (MFP-NU-WL p. 19) commonly range broadly 
across upland forests ranging in age from clearcuts to old-growth stands. 
Only the spotted owl remains, and its habitat requirements have been discussed. 
Elk are doing well under a fragmented forest-island habitat that the corridor 
system supposedly would correct. From RAA-DR-WL (p. 19) the following sentences 
are quoted, "The present distribution of elk in western Oregon is characterized 
by population concentration centers which occur as islands across forest lands 
of varying serai stages. The lack of elk in some seemingly acceptable habitat 
has remained unexplained." 

At this time the proposed corridor system is a test or experiment and as yet 
an essentially unplanned experiment. Wildlife habitat management plans and 
PAA analysis have not been completed for corridor lands. The option to form 
a corridor system will never be foreclosed because mature and older forests 
are renewable. Extinction is not an issue for no species in the SYUs are 
found only in the Roseburg District or are threatened by extinction. During 
this time of recession and budgetary restraint, a corridor system is a costly 
experiment with little chance of fulfilling the intended purpose because of 
the checkerboard nature of OiC lands. 



Although it is presented in an off-hand, low-profile manner, apparently a 
corridor system is envisioned for the SYUs. Attempts to overlap and joint-use 



E. Summary of Old-Growth and Wildlife Acreage 

What is sufficient old-growth forest to meet wildlife 



eeds is not easily 



68-9| 
68-10 



answered. The DEIS makes the statement (p. 74) that only Alternatives 6, 7, 
and 8 would maintain, over the long-term, populations of animals whose optimum 
habitat is mature and old-growth habitat. From Table 3-9 this would be interpreted 
that currently enough is known about old-growth species to say that 100 years 
from now 70,000 acres of old-growth forests will be required. The accuracy 
of this long-term prediction based on the present scant data Is highly questionable. 
Elk populations would only decline 20% (Tab. 1-5) in Alternatives 4 and 5. 
Would this be past the population threshold and elk would cease to exist in 
,the SYUs? Eighteen pair of spotted owl (Tab. 1-5) would remain at 100 years 
lunder Alternatives 3 and 4. Is the spotted owl not then a good old-growth 
|indicator species? From what is known it has larger and more stringent old- 
growth habitat requirements than other species. According to the DEIS (p. 71), 
Alternatives 3 and 4 would also "provide an adequate representation of the 
original old-growth systems." Yes, prediction of habitat for wildlife populations 
a century in the future is filled with possible errors. 

Hence, whether for spotted owls, elk habitat, or corridors, there seems to 
be little prudent support for allocating Commercial Forest Land to a Constrained 
Timber Production Base for wildlife purposes. The amount of forest timber 
harvest lost under the Constrained Base is significant. This EIS for the 
Timber Management Plan "Is considered applicable for the decade . . ."(DEIS 
p. 26). At the end of the ten-year period a more accurate assessment of wildlife 
needs will be possible. Unreasonable demands have been placed on wild] 
biologists the past five years to categorize and quantify wildlife habitat. 
Studies of old-growth systems themselves have been recent (DEIS p. 42), let 
alone studies on animals and relationships within the old-growth system. Many 
of the guesses, best estimates, assumptions, district biologists' opinions, 
etc., can in a decade be sound biological fact with resultant sound resource 
allocation. Meanwhile, during the next decade habitat alteration will not be 
extensive enough to harm knowingly any species or community. 



Ill ELK AND ROAD SYSTEMS 



Harrassment of wildlife (elk)by vehicles is at this time a confusing, 
understood subject. Research does present conflicting results, but more impor- 
tantly the visual experience of many people who regularly see elk along major 
highways makes it difficult to convince the public that elk use is significantly 
affected within h mile along each side of lightly used logging roads. The 
following quotation from the August 8, 1982, Oregonian illustrates this point: 
Tourists are getting an eyeful on coastal highways and b 
this summer, as Roosevelt elk wade across the country scenery amid 
farms and cattle. 

The accompanying photograph, for example, was taken a] 
U.S. 101, a mile south of Tillamook, where this four-point bull 
has adopted a herd of young dairy princesses. 

It's not common, but neither is it unusual, for elk bulls 
to act this way, say biologists. The paternal instincts wear off 
with time, as the elk realizes his adopted charges don't re 
care about him one way or another. 

The Reedsport herd has also been regularly hanging around 
its usual field haunts alongside Oregon 38, a few miles east 
town. 

Wildlife biologists also seem to have a difficult time accepting elk avoidance 

of habitat near roads. Hershey and Leege (1976) used truck and trailbike 

to observe elk on eleven of eighteen observation routes and more recently 

BLM and ODFW employees Smithey, Wisdom, and Hines (1982) conducted a study 

on Roosevelt Elk and Black-tailed Deer Response to Habitat Changes Related 

to Old-growth Conversion in South Western Oregon . The study was conducted 

by road counts. If elk avoid using habitat near roads, roadside census techniques 

would be highly inaccurate. 



The scientific literature is conflicting. Studies rrass- 

ment is significant are summarized by Irwin and Peek (1979), Lyon (1979), 
Pedersen et al. (1979), and Perry and Overly (197(. the studies referred 

to were on Rocky Mountain elk east of the Cascade Range where "topography 



15 - 



122 



ili deap valleys and high steep ridges . . ."(Perry and Overly 
1976 p. 62). In addition to larger topography, vegetation is more sparse In 
these areas than in the Coast Range. For example, old-growth stands in Northern 
Idaho had a visibility radius of 100 feet while second-growth stands had a 
visibility radius of 40 feet. Hence, young-growth stands were used as hiding 
cover more than other vegetation types (Irwin and Peek, 1979). Ward (1976) 
concluded that "as long as the vehicle is moving, elk apparently feel relatively 
safe"(p.38). In this particular four-year study In Wyoming, elk were seen 
or telemetery located 44 times from the road to 200 yards, 34 times from 200 
yards to 440 yards, 56 times from 440 yards to 880 yards (twice the distance), 
and 57 times from 880 yards to 1760 yards (four times the distance). According 
to this report, per amount of area, elk used area near the roads more than 
area farther away. The conclusion of a study on roads and wildlife in Arizona 
was "In late summer and fall, traffic increased significantly. However, it 
is doubtful that this increase has an adverse effect on wildlife production 
. . ."(Burbridge and Neff 1976 p. 56). Schoen (1977) found heavy use of roads 
as travel routes in western Washington during the winter whether the roads 
had been plowed or not and also stated, "Wapiti have frequently been observed 
within 300 feet of a moderately used road, separated by cover, and appeared 
to show little concern for vehicular traffic unless a vehicle stopped . . 
."(p. 199). To continue from this same western Washington study, "on the whole, 
especially in areas where dense vegetation provides cover and/or impedes travel; 
it appears that wapiti will use low traffic or closed roads as travel lanes 
or trails . , ."(p. 200). Shoen also noted that displacement movements by 
current logging operations were usually one-half mile or less and that elk 
were often observed within one-half mile of active logging when shielded by 
vegetative cover or topography. Elk in Olympic National Park were observed 
by Jenkins and Starky (1980) to bed often in spruce-hemlock stands within 
audible range of human voices and traffic and appeared to be accustomed to 
activity on the road. 



be the most abundant habitat type on the SYUs in future yearn (DEIS App 
Proper road and vegetation management would certainly narrow the impact zone 
of roads on elk. "Losses to thlB cause (harrassment) would not be expected 
to be large or significant to the population as a whole. . . ."(OBIS p. 72) 
could readily be applied to the use of elk habitat and roads. 

In brief, road systems may reduce elk use of nearby habitat under open, long- 
sight-distance, high-traffic conditions. At the same time, smaller topography, 
rapid revegetation, abundant hiding cover, and low-vehicular traffic permit 
elk use nearer to road systems. Elk with a comparatively large home range 
can easily move away from a road during periods of traffic or during the day 
and then move nearer the road at night or low-traffic times to use the hat- 
Not only do 13-to- 30-year-old trees provide hiding cover, but darkness (Pedersen, 
1976) is also a ubiquitous reliable hiding cover. Besides being hiding cover, 
darkness is also thermal cover as shown by the statement, "Elk used clearcut 
areas at night but preferred the security and milder temperatures of dense 
conifer stands during the day" (Edgerton and McConnell 1976 p. 5). Schoen 
(1977) found that elk actually preferred open regions (clearcuts) at night. 
Broad generalized statements that elk use is reduced within one-half mile 
of roads and that up to 75% of an area would have reduced elk use because 
of roads are extrapolation of data from a different elk in a different topography, 
OO II In different vegetative types, and in different climates than the Coast Range. 
Management of roads and of forest treatment practices and applying what is 
known about elk behavior to a specific area (as the Tyee Area) can greatly 
limit road-elk conflict. 



Some interruption of normal elk behavior due to vehicular harrassment does 
occur under certain circumstances. Pedersen (1979, 1979b) and Black et al. 
(1976) have road management recommendations that are being incorporated Into 
the Tyee Area to reduce conflict. Hiding and escape cover (DEIS p. 45) will 



to significantly affect the stand or species compositio 
Area"(DEIS p. 70). 



of the entire Roseburg 



IV INTENSIVE FOREST MANAGEMENT AND WILDLIFE 



Intensive forest management is the basic premise of the Proposed Action: 249 
MM bd. ft. from 333,319 acres of Commercial Forest Land compared to the No 
Change Alternative with 201 MM bd. ft. from 390,984 acres. Wildlife and their 
habitat will be influenced by intensive forest management, yet as a whole 
the impact will be localized and will not be severe. Important habitat areas 
for special uses or special species are protected by MFP withdrawals in all 
alternatives except 5. Additional protection for other specialized uses is 
allocated as Constrained Timber Production Base in all alternatives except 
1 and 5. Not every forest management treatment will be applied to every acre 
of Commercial Forest Land (DEIS p. 19), and as an example Alternative 2 has 
63,000 acres that are not in the intensive timber harvest base. It is worthwhile 
examing some of the forest treatments and the result of these treatments on 
wildlife. 

A. Slash Burning 

Slash burning eliminates most live vegetation and associated animal populations 
for a short time. Nevertheless, "this would last less than one growing season, 
after which a vigorous growth of grasses and forbs would appear and animal 
populations adapted to early successional-stage vegetation would be reestablished" 
(DEIS p. 76). Forage for elk and deer is generally increased and woody material 
that obstructs large animal movement is reduced. As a whole, burning impacts 
are very short term with subsequent enhancement for important game species. 
The trend toward spring or fall light burns reduces impact. 

B. Artificial Regeneration 

Artificial regeneration usually accelerates succession through early stages, 
but since cutting will continue, other acres will be continuously beginning 
early succession. A rotating source will be available. Impact is summarized 
by "the artificial regeneration program on BLM-administered lands is not expected 

- 18 - 



68-12 



68-13 



C. Precommercial Thinning 

Precommercial thinning is credited with increasing bird and small mammal use 

but hindering deer and elk movement. Crouch (1974) is the reference cited 

in the DEIS for the conclusion that slash impedes deer and elk movement. The 

article is entirely on deer; the word elk is not even used so this reference 

is not applicable to elk. On the other hand, Swanson (1970) does write that 

sites with moderate amounts of logging debris generally received most elk 

use and those with heavy amounts, the least use. Areas of patchy debris distribution 

had more use than sites with uniform debris distribution. Whether or not 

precommercial thinnings present a major obstruction to deer or elk would depend 

mainly upon the pre-thinning density of the stand. Precommercial thinning 

after trees are too large (15 years?) or on extremely dense stands (2,000 

stems per acre) can restrict potential habitat use. Berg (1969) noted that 

slash from precommercial thinning was quickly beaten to the ground and in 

2 to 3 years the fine material is decomposed enough so that slash debris is 

not a problem. Since only an average of approximately 11 of the SYUs acreage 

would be precommercially thinned in any one year, it would not cause a significant 

habitat impact. 

D. Fertilization 

Fertilization proposed at 10-year intervals with impacts lasting for an average 
of 7 years (DEIS p. 70) will increase growth and palatability of many plant 
species (DEIS p. 77). This will provide additional forage for wildlife and 
will hasten the decomposition of thinning slash. 



E. Commercial Thinning 

Commercial thinning, between 30 and 60 years, that removes 30Z to 40* of the 
basal area is discussed In the DEIS as resulting in lower deer and elk populations. 
Edgerton (1972) and Edgerton and McConnell (1976) studies In northeastern 
gg-14|0regon are ciced. Not all research has reached the same conclusion. Partial- 
cuts were more acceptable to elk than clearcuts in western Montana (Marcum 
1976); in northern Idaho, stands treated by shelterwood method produced nearly 



123 



as much herbaceous cover as clearcuts (Irwin 1976); in Arizona, selective 

cutting increased understory vegetation for 11 to 15 years (Reynolds 1962); 

in northeastern Oregon, timber stands with less-dense cover were used as forage 

a. 

areas (Pedersen 1979); In western Washington, elk during the summer used open 
and sparse canopy habitat-types in the same proportion in which they occurred 
while closed canopy habitats were avoided (Schoen 1977). 

Thus, a total negative impact of partial-cuts on elk and deer is questionable. 

The habitat type, the location, the climate, the adjacent land use and other 

variables must be considered. Under many situations commercial thinning may 

be more helpful than harmful to wildlife. The balance between forage and 

cover habitats and available supply of both along with the ability of deer 

and elk to move between habitats in order to maintain this balance is complex. 

An overall negative influence upon wildlife Is not supported by existing biological 

data. 

An impact of commercial thinning upon selected birds is also indicated in 
the DEIS. The authority cited is Franzreb and Ohmart (1978), a study in Arizona 
that compared bird life in an area before and after logging. Before logging, 
density was 896 trees per acre; after logging, density was 268 trees per acre. 
Even though the total bird population was far smaller in the partial-cut area, 
thinning led to an increase in tree-species diversity and no change in bird 
species diversity. So tree thinning reduced total bird population but not 
the number of bird species. In a study in New York where 25%, 50%, 75%, and 
100% of the trees were removed by logging, Webb et al. (1977) concluded that 
no bird species was eliminated by logging and that "numbers of species and 
diversity indices were higher in logged areas and were positively correlated 
with increased logging intensity" (p. 32). Areas with 25% and 50% tree removal 
would be comparable to commercial thinning. Mauer et al. (1981) noted that 
the difference in bird populations between a selective-cut area and a mature 
forest was the addition of early-regrowth adapted species to the already present 
mature-forest adapted species. The two-bird communitites remained very similar. 
From another study the conclusion was "in summary, we found few differences 
in the total density or richness of the breeding birds of a hardwood forest 
that was affected by several forestry practices, including clear-cutting, 



strip cutting, and thinning" (Freeman et al. 1981 p. 310). Obligate forest 
birds had intermediate mixtures in thinned plots where thinning was removal 
of 45% of the basal area. Szaro and Balda (1979) recommend that only 30% 
of the basal area be removed to maintain and/or increase bird populations 
in a Ponderosa pine forest. 

Commercial thinning is also credited with Impacting nesting of Cooper's and 
sharp-shinned hawks. Jactaan and Scott (1975) list seven out of ten sharp- 
shinned hawk nests as being in young, even-aged conifer stands with single- 
layered canopies while Cooper's hawks nested in Douglas-fir sjres with a mean- 
stem density of 217 per acre. The latter density of 217 trees per acre (approximately 
15 feet apart) is not a particularly dense stand. In fact, this af ter-thinnlng 
tree density (approximately 200 trees per acre) is nearly the same den 
used in the DEIS to Indicate that commercial thinning is harmful to accipiter 
nesting habitat. Similarly, the other reference to indicate commercial thinning 
harms bird habitat (Franzreb and Ohmart 1978) had an after-thinning density 
of 268 stems per acre. The logical conclusion is that the thinned forest 
habitat in the latter has more stems per acre (268) than the dense (as referred 
to in the DEIS p. 74) habitat (217) in the previous reference. In other words, 
density is relative. 

Commercial thinning of 20% to 50/. of the basal area can alter forest habitat. 
But as has been shown by the previous references, the impact may or may not 
occur. It may be positive or negative. It often is slight. And it is species 
specific, but overall does not eliminate species. Obviously, broad statements 
that commercial thinning has negative impact are not supported by biological 
evidence. Also, to be remembered is that on an average only approximately 
0.1% of the Timber Production Base will be commercially thinned each year. 

Intensive forest management treatments will, as a whole, not significantly 
impact wildlife. Animals will temporarily compress or expand home ranges 
and increase or decrease population levels over the short term as habitat 
is available. Wildlife is adaptable and is capable of moving to avoid or 
to use changing habitats whether the habitat is changed by succession or by 



managed treatment. Two statements in the DEIS are worthy of note on this 
subject. Intensive timber management practices will not^ eliminate hardwood 
trees, shrubs, and herbaceous vegetation (p. 72), and "vegetation which is 
disturbed or destroyed by timber management activities would eventually be 
replaced by other plants of the same species and natural succession would 
restore community structure until the next harvest stage" (DEIS p. 71). Therefore, 
treatments may alter vegetation, but natural succession will return the same 
species to the treated areas. 



V RIPARIAN AREA MANAGEMENT AND FISHERIES 



Riparian areas and their management as proposed under Alternatives 2, 3. <. , 
and 7 will adequately meet the many uses of the streamside acres. The 18,332 
of riparian, plus 3,682 acres of VRM II, plus 2,772 acres for osprey and heron 
provide 24,786 acres that are essentially riparian area. In addition, the 
2,912 acres that are completely protected for bald eagle would also be mainly 
riparian area. The small acreage proposed for clearcut and partial-cut would 
not disrupt the integrity of the riparian system and its many functions while 
still permitting multiple-use in the form of limited, regulated timber harvest. 
Sediment would be trapped by the riparian areas under Modified Area Control 
as indicated (DEIS p. 68), and no increase in stream water temperature would 
be expected as indicated on p. 78. Forest harvest along first- and second- 
order streams is cutting vegetation that is more like upland habitat than 
riparian habitat (DEIS p. 75); hence, possible impact is lessoned. 



Habitat improvements of various types as suggested in the MFP-Fisheries will 
improve the instream fishery habitat and blockage removal will open new habitat. 
Much of the low summer water flow is a result of domestic and agricultural 
use over which BLM has little control. 



6815 



The summary statement on environmental consequences (DEIS p. 79) does not 

to agree with data presented. Fish populations would be expected to dt- 

under Alternative 1, 2, and 3 because of increased temperatures and sedimentation, 

and under Alternativew 4 , 6, 7, and 8 fish populations would increase. In 

contrast, the DEIS (p. 78) states, "Water temperatures would not increa 

Alternatives 2, 3, 4, 6, 7, or 8 were selected." The difference in amount 

of sediment between Alternatives 3 and 4 is only 3". With the current st3te 

of the art, it is impossible to predict the influence of sediment upon fishes 

with anywhere near a plus-or-minus-3'; accuracy. 



23 - 



124 



68 16 



In addition, the statement (DEIS p. 75) that the proposed management of riparian 
areas for Alternatives 2, 3, 4, and 7 would substantially alter riparian habitats 
can be questioned. Carefully controlled partial-cut (and other management 
restrictions) on (>X of the total riparian acres and clearcuttlng of 0.072 
annually could hardly produce substantial alteration on the whole riparian 
area. The proposed riparian areas and their management under Alternatives 
2, 3, 4, and 7 will maintain and enhance terrestrial wildlife, snag-dependent 
species, water quality, streambank protection, and fish populations. 



VI CONCLUSIONS 



(1) BLM is commended for considering and applying some innovative management 
and for the Improvement of this DEIS over previous Environmental Statements. 

(2) Acres allocated for the Intensive Timber Production Base are of prime 
Importance as the foundation of timber harvest. 

(3) Acres removed from the Intensive Timber Production Base under all alternatives 
except 1, 2, and 5 are major and significant. 

(4) The SYUs presently have 47£ of Che area in mature and old-growth forests; 
this acreage will remain high under all alternatives through the first decade. 

(5) A comparatively high number of owls exist in the SYUs and will remain 
high through the first decade. 

(6) Much is not known about spotted owls and about old-growth forests with 

the consequence that the relationship between wildlife and old-growth is unclear. 

(7) The spotted owl is not listed nor has It been proposed for listing under 
the Federal Endangered Species Act. In fact, the FWS says that the spotted 
owl would not qualify for Federal listing. 

(8) For the next decade, allocation of resources solely for the spotted 
owl seems unnecessary and ill-advised. 

(9) It has not been shown that elk must have old-growth forest as survival 
cover. Because elk are adaptable, no decline in harvest is projected during 
the next two decades. 

(10) During either summer or winter, elk respond to weather conditions by 
diurnal or longer movemenCs to locations that fill their temperature needs. 
These cover needs can and often are met by habitat types other than old-growth 
habitat. 

(11) A proposed wildlife corridor system has little chance of functioning 
because of the checkerboard nature of BLM lands. 

(12) A corridor system is a costly and essentially unplanned experiment. 

(13) For any of the reasons reported in the DEIS, there seems little prudent 
support for allocating old-growth foresc to a Constrained or Non-harvest Base 
for wildlife purposes. 

- 25 - 



(14) A generalized statement that elk-habitat use is noticeable reduced by 
logging road systems is not supported by common knowledge nor by the literature. 
Road harrassment impacts may be much less than presented in the DEIS. 

(15) Intensive forest management may be either helpful or harmful to wildlife 
habitat. Negative influence, if present, is nearly always short-lived and 
localized. 

(16) Succession will, over time, return Che same plant and animal community 
to a management-treated area. As a result, old-growth forest is a renewable 
resource. 

(17) Acres allocated and management proposed for the riparian areas will 
adequately protect and enhance the many important uses associated with streamside 
and downstream areas. 



LITERATURE CITED 



Beall, R. C. 

1974. Winter habitat use by a western Montana elk herd. 
Univ. Mont., Missoula. 



Ph.D. Thesis. 



Beall, R. C. 

1976. Elk habitat selection In relation to thermal radiation. I_n Proceedings 
of the elk-logging-roads symposium, p. 97-100. Univ. Idaho, Moscow. 



Berg, A. B. 

1969. Thinning in precommercial stands. 
Northwest, p. 79-87. Coop. Extension Ser 



Woodland handbook for the Pacific 
Oreg. State Univ., Corvallis. 



Black, H. , R. Scherzinger, and J. W. Thomas 

1976. Relationships of Rocky Mountain elk and Rocky Mountain mule deer habitat 
to timber management in the Blue Mountains of Oregon and Washington. lr\ 
Proceedings of the elk-logging-roads symposium, p. 11-31. Univ. Idaho, Moscow. 

Burbridge, W. R. and D. J. Neff 

1976. Coconino National Forest — Arizona Game and Fish Department cooperative 
roads — wildlife study. _In_ Proceedings of the elk-logging-roads symposium, 
p. 44-57. Univ. Idaho, Moscow. 

Crouch, G. L. 

1974. Interaction of deer and forest succession on clearcuttings in the 
Coast Range of Oregon. I_n Wildlife and forest management in the Pacific 
Northwest, p. 133- 138. Oreg. State Univ., Corvallis. 

deCalesta, D. S. and G. Witmer 

1980. The relationship of stand development to habitat requirements of elk 
in the Douglas-fir region of the Coast Range of Oregon. Final Report, FW-PNW- 
Grant No. 18, 58 p. + tab. and fig., Dept. Fish and Wildl. , Oreg. State Univ., 
Corvallis. 



Edgerton, P. J. 

1972. Big game use and habitat changes in a recently logged mixed conifer 
forest in northeastern Oregon. Proceedings 52nd Annu. Conf. West. Assoc. 
State Fish and Game Coram., p. 239-246, Portland, Oreg. 



Edgerton, P. J. and B. R. McConnell 



gerton, P. J. and B. R. McConnell 

1976. Diurnal temperature regimes of logged and unlogged mixed conifer stands 

on elk summer range. USDA For. Serv. Res. Note, PNW-277. 6 p. Pac. Northwest 

Vnr- 9nA D-inas Pvn ^f-n Pnrfl anrl Or«a 



. range 
For. and Range Exp. Stn 



Portland, Oreg. 



125 



Franzreb, K. E. and R. 0. Ohnart 

1978. The effects of timber harvest on breeding birds 
forest. Condor 80:431-^11. 



nixed coniferous 



Freedraan, B., C. Beauchanp, I. A. McLaren, and S. I. Tingley 

1981. Forestry management practices and populations of breeding birds in a 
hardwood forest in Nova Scotia. Can. Field-Nat. 95(3) :307~31 1 . 

Harshman, E. P. and R. N. Jubber 

1980. Roosevelt elk and blacktailed deer guidelines for timber, recreation, 
and road management. (Draft) 63 p. Willamette Nat'l. For. and ODFW. 

Hershey, T. J. and T. A. Leege 

1976. Influences of logging on elk on summer range in north-central Idaho. 
In Proceedings of the elk- logging-roads symposium, p. 73-80. Univ. Idaho, 
Moscow. 

Irwin, L. L. 

1976. Effects of intensive silviculture on big game forage sources in northern 
Idaho, In Proceedings of the elk- logging-roads symposium, p. 135-142. Univ. 
Idaho , Moscow. 

Irwin, L. L. and J. M. Peek 

1979. Relationship between road closure and elk behavior in northern Idaho. 
In North American elk: ecology, behavior and management, p. 199-205. Univ. 
Wyo. , Laramie. 

Jackman, S. M. and J. M. Scott 

1975. Literature of twenty-three selected forest birds of the Pacific Northwest. 
USDA For. Serv. Reg. 6. 382 p. Portland, Oreg. 

Jenkins, K. and E. Starkey 

1980. Roosevelt elk of the Hoh Valley, Olympic National Park. Final Report, 
Contract No. CX9000-7-0085, NPS, Oreg. Coop. Park Studies Unit. 32 p. Oreg. 
State Univ., Corvallis. 

Leege, T. A. and W. 0. Hickey 

1977. Elk-snow habitat relationships in the Pete King Drainage, Idaho. Bull, 
No. 6. 23 p. Idaho Dept. Fish and Game, Boise. 

Lyon, J. L. 

1979. Habitat effectiveness for elk as influenced by roads and cover. Jour. 
For. 77(10) :658-660. 

Mandel, R. D. and D. W. Kitchen 

1979. The ecology of Roosevelt elk in and around Redwood National Park. 69 p. 
Park Contract PX8480-8-0045. Humbolt State Univ., Areata, Calif. 

Marcum, C. L. 

1976. Habitat selection and use during summer and fall months by a western 
Montana elk herd. _In Proceedings of the elk-logging-roads symposium, p. 91-96. 
Univ. Idaho, Moscow. 



Martinka, C. J. 

1976. Fire and elk in Glacier National Park. In Proceedings tall timbers 
fire ecology conf. No. 14:377-389. 

Maurer, B. A., L. B. McArthur, and R. C. Whitmore 

1981. Effects of logging on guild structure of a forest bird community in 
West Virginia. Amer. Birds 35(1):11-13. 

Pedersen, R. J. 

1976. Pre-logging elk habitat use. In Proceedings of the elk-logging-roads 
symposium, p. 85-87. Univ. Idaho, Moscow. 

Pedersen, R. J., A. W. Adams, and J. Skovlin 

1979. Elk management in Blue Mountain habitats. Report, Research and Develop- 
ment Section, ODFW. 27 p. Portland, Oreg. 

Pedersen, R. J. 

1979a. Northeast Oregon elk research. Oreg. Wildl. 34(11) :3-5. 

Pedersen, R. J. 

1979b. Management and impacts of roads in relation to elk populations. In 
Recreational impact on wildlands: Proceedings of a conference, p. 169-173. 
USDA For. Serv., Pac. Northwest Reg., Portland, Oreg. 

Perry, C. and R. Overly 

1976. Impact of roads on big game distribution in portions of the Blue Mountains 
of Washington. Jto Proceedings of the elk-logging-roads symposium, p. 62-68. 
Univ. Idaho, Moscow. 

Reynolds, H. G. 

1962. Effect of logging on understory vegetation and deer use in a ponderosa 
pine forest of Arizona. USDA For. Serv. Res. Note RM-64. 3 p. Rocky Mt. For. 
and Range Exp. Sta. , Fort Collins, Colo. 

Schoen, J. W. 

1977. The ecological distribution and biology of wapiti (Cervus elaphus nelsoni ) 
in the Cedar River Watershed, Washington. Ph.D. Thesis. 406 p. Univ. Wash., 
Seattle. 

Smithey, D. A., M. J. Wisdom, and W. H. Hines 

1982. Roosevelt elk and black-tailed deer response to habitat changes related 
to old-growth conversion in south western Oregon. Northwest Sec. Wildlife Soc. 
Paper, presented in symposium on wildlife relationships in old-growth forests. 
Juneau, Alaska. 

Swanson, D. 0. 

1970. Roosevelt elk-forestry relationships in the Douglas-fir region of the 
Southern Oregon Coast Range. Ph.D. Thesis. 173 p. Univ. Mich., Ann Arbor. 

Szaro, R. C. and R. P. Balda 

1979. Effects of harvesting ponderosa pine on nongame bird populations. USDA 

For. Serv. Res. Pap. RM-212. 8 p. Rocky Mt. For. and Range Exp. Stn. , Fort Collins, 

Colo. 



status review. USDI, FWS , Endangered Species 



U.S. 7ish and Wildlife Service 
1982. The northern spotted owl: 
Program. 29 p. Portland, Oreg. 

Ward, a. L. 

1976. Elk behavior in relation to timber harvest operations and traffic on the 
Medicine Bow Range in south-central Wyoming. In Proceedings of the elk-logging- 
roads symposium, p. 32-43. Univ. Idaho, Moscow. 

Webb, W. L., D. F. Brehrend, and B. Saisorn 

1977. Effect of logging on songbird populations in a northern hardwood forest 
Wildl. Mono. No. 55. 34 p. The Wildl. Soc. 



Mason, Bruce & Girard. Inc. 
Consulting Foresters 



and, Oregon 97305 



August 20, 1982 



Mr. Robert E. Ragon 
Vice President 
Sun Studs, Inc. 
P. O. Box 1127 
Roseburg, Oregon 97 470 

Dear Mr. Ragon: 

This is our review of the Roseburg Timber Management Draft 
Environmental Impact Statement. It contains our analysis based 
on your request to examine the relative economic efficiency of 
specific alternatives and possible intensive management funding 
problems the BLM might face when implementing its preferred alter- 
native. 

We believe this draft environmental statement shows con- 
siderable improvement over other BLM environmental statements 
we have reviewed. The BLM staff at Roseburg was very helpful 
in providing useful information and answering our requests. If 
you wish we will be willing to answer any questions or clarify 
any points for the BLM about our analysis. 



68 17 



Summary and Recommendations 

1. Current low timber sale contract prices and delays in 
harvest due to depressed wood products markets indicate the BWs 
forecasted revenues in 1984, 1985 and 1986 are too high. Pro- 
jected management costs may exceed 25 percent of such reduced 



126 



Mr. Robert E. Ragon 

AuqUiit- 20, 

Page 2 

luction in 

5 which support the hi el of 
cut . 

unmendation - The BLM should carefully potenl Lai 

i 1 be aware of potent i 
problems. Selection of Alternative 2 would alleviate this 
possible problem by maintaining a larger land base. 

2. A comparison of first decade management costs between 
Alternatives 2, 4 and 5 show that the costs per MBF of harvest 
are lowest for Alternative 2 . Also, we show that intens ive 
forest management costs are a small percentage of the total 
budget. A small change in the funding level could substantially 
impact the intensive management program. Under the preferred 
Alternative 4 such a reduction could cause the harvest level to 
fall below recent past levels. This is not true for Alternative 
2. 

Recommendation - Select Alternative 2 . 

3. The benefit/cost ratio of first decade management is 
higher for Alternative 2 than Alternative 4. The effects of 
intensive management are highly significant . Without intensive 
management the Alternative 2 benefit /cost ratio would drop from 
8.5 to 1 to 6.3 to 1. The intensive management program in Alter- 
native 2 results in an increased annual allowable harvest of 89 
million board feet. This would generate an additional $175 
million in the first decade on an expenditure of about $6.6 



68-18 



Mr . Robert E. Ragon 
August 20, 1982 
Page 3 

Lon. if funding for 
an additional 176,000 acres of naturally grown forest wouli 
needed to sustain the same harvest. 

Recommendation - The intensive management program 
critical part of any management program on the Roseburg District 
and the funding necessary for implementation should receive 
first priority. 

4. The costs per acre for reforestation reported by the 
Roseburg District are significantly higher than those of other 
land managers in the area. Other costs per acre of management 
practices are more in line. 

Recommendation - The Roseburg District should institute a 
program aimed at cost reductions on all reforestation activities. 

5. The land base is very important as a basis for sustained 
increases in harvest levels on the Roseburg District. Lands 
proposed for management under an extended rotation must have 5 
times more area to support a one million board foot annual harvest 
level than under an intensive management regime. We recommend that 
the BLM should use other means than extended rotations or use 
rotations shorter than 250 years in order to provide for other 
resource values . 

6. The Soil Expectation Values {SEVJ contained in the 
environmental statement were not used in selecting management 
regimes, or if they were, other unstated criteria were controlling 
selections. Also, we question some of the methods used and are 
concerned about the implications of the low and negative values. 



68 19 



68 20 



Mr . Robert E . Ragon 
August 20, 1982 
Page 4 



Recommendation - The BLM should reexamine the purpose and 
usefulness of SEV's in preparing the plan and limit their pre- 
sentation in the EIS to a few critical values or regimes as they 
relate to the final selection of management regimes. SEV's should 
be determined with a 4 percent discount rate which gives greater 
weight to more distant values and costs, thus reflecting govern- 
ment ' s concern for future generations . 

Financing Intensive Management 

There is a critical relationship between forecasted timber 
revenue and estimated timber management budgets on these O & C 
lands. Management on O (, C lands is traditionally financed from 
a share of the stumpage receipts. Furthermore, current federal 
budget deficits are forcing agencies to place greater emphasis 
on the efficiency of alternative investments in order to justify 
expenditures regardless of source of funds. This situation is 
further complicated by the fact that current timber sale con- 
tracts are not being logged in a timely fashion due to the de- 
pressed markets, and some may not be logged or will be extended. 

Because of this critical relationship we are concerned about 
preferred alternative which relies on intensive management 
expenditures for maintenance of a high level of harvest volume. 
Tabic B-2 on page 116 of the DEIS significantly overstates both 
the revenue and cost levels that can be expected during the next 
10 years. First, the forecast revenues for 1984 through 1987 
appear to us to be too high. If one assumes an approximate 3 
year lag between timber sale date and the harvest date, the har- 

Mason Bruce ft Gm*»o Inc 



68 20 



Mr. Robert E. Ragon 
August 20, 1982 
Page 5 

st values of $302 per MBF during 1984 are far too high. The 
erage price of timber sold on the Roseburg District in 1981 
was $259 per MBF and to date in 1982 the average price is $130 
per MBF. These are the sales that will be cut and paid for 
during 1983 and 1984. 

Also, the harvest levels shown in Table B-2 overstate what 
reasonably could be expected to be harvested during 1984 to 1986. 
The BLM will not begin to sell its higher proposed allowable 
harvest volume until 1984. Consequently, none of this increased 
volume will be harvested until about 1987. 

The estimated forest management costs shown in Table B-2 
do not adequately reflect the actual acres that are to be treated 
in the initial part of the decade. In particular, the increased 
planting acreage shown by BLM will not be necessary until some- 
time after 1987 when the increased harvested areas actually are 
ready for planting. 

We have made a revised estimate of sales volume and projected 
revenues and costs in Exhibit 1. In our opinion these are more 
realistic estimates of the sales volumes and values to be expected 
during the next 3 years. Exhibit 1 also includes an estimate of 
actual harvest levels for 1982-84 and two levels of estimated 
harvest values per KBF for 1984-86. Based on these estimates 
it is our opinion there is a possibility that 25 percent of the 
receipts from timber harvest would not be sufficient to fund 
the estimated forest management costs shown in the BLM Table B-2. 



68 21 



Mr. Robert E. Ragon 
August 20, 1982 
Page 6 



As a result we recommend that the BLM more closely evaluate 
potential income flows against estimated costs. Final plans 
should provide for such a contingency in order to insure a con- 
tinued high level of annual timber harvest. 

Economic Efficiency of Alternatives 

Forest management costs should be carefully examined in 
relation to the benefits in terms of harvest volumes produced. 
The BLM planning does not clearly present this relationship for 
each alternative. We have displayed the first decade costs for 
forest management for three of BLM's alternatives in our Exhibit 2. 
The bottom line reveals that the management costs per MBF pro- 
duced by Alternatives 2 and 4 are 6 percent less than those of 
Alternative 5. Alternative 2 has the lowest per MBF cost and 
by that criteria would be the best. Exhibit 2 also shows that 
the major expenditures in Alternatives 2, 4 and 5 (other alter- 
natives are similar) are for planting, replanting and sale preparation 
and administration. These are basic activities and do not include 
the intensive management costs of precommercial thinning, genetics, 
fertilization, etc. In Alternatives 2 and 4, ninety percent of 
the total management expenditures occur in these basic activities. 
In contrast, 97 percent of the total management expenditures in 
Alternative 5 (the present situation) are related to planting, 
replanting and timber sale preparation and administration. The 
intensive forest practices proposed in either Alternative 2 or 
4 make up the balance of the total costs, or about 10 percent. 



127 

Mr. Robert E. Ragon 
August 20, 1982 
Page 7 

This is a small percent of the total manag ires 

required. Yet, these expenditures will generate a very substai 
increase in the allowable harvest r 

Economic Efficiency of Intensive Practices 

Total costs and total revenues cannot be used alone to compare 
the relative efficiency of alternative plans nor of forestry prac- 
tices within plans. We have examined ncy using 
benefit/cost ratios for only the first decade and have isolated 
intensive management effects on the ratios. In a comparison of 
Alternative 2 and the BLM preferred Alternative 4, we found tl 
Alternative 2 had the highest benefit to cost ratio. (See Exh 
3. ) Alternative 2 provides about $526 million in disco 
decade revenue against discounted costs of $61 mil!. 
ratio of 8.5 to 1. The BLM's preferred alternative would pro- 
duce about $490 million in discounted first decade reve; 
discounted costs of $58 million and a ratio of 8.4 to 1. 

In order to measure the effects of intensive management, 
examined Alternative 2 under the assumption that funds mi 
not be available in the first decade to implement the planned 
intensive forest management practices . These practices included 
genetic planting, precommercial and commercial thinning and ferti- 
lization. These practices require only about 10 percent of the 
expected first decade costs in Alternative 2. But reduced stumpage 
revenue early in the decade is a possibility as noted earlier. 
If this should happen, a likely candidate for cost savings would 
be the intensive practices. However , we would not recommend such 



Mr. Robert E. Ragon 
August 20, 1982 
Page 8 

action because of the critical and highly productive responses 
to intensive management in terms of increased harvest . Our 
analysis results in Exhibit 3 shows the impact of intensive 
practices. Without these the benefit/cost ratio for the first 
decade in Alternative 2 is reduced from 8.5 to 1 down to 6 . 3 
to 1 . A similar reduction could be expected without the intensive 
practices in BLM's preferred Alternative 4. 

The great importance of the intensive management funding 
is further illustrated in Exhibit 4. The annual harvest of 
Alternative 2 is increased by 8 9 million board feet because of 
intensive management. The benefit/cost ratio of the first decade 
intensive management program is 26.3 to 1. 

The impacts of the intensive management program on the 
harvest level (often called the allowable cut effect) was 
estimated because time did not permit use of BLM's SIMIX model. 
We considered only the first decade harvest impacts as shown 
in Exhibit 4. The total first decade harvest increase due to 
an intensive management program was allocated to the several 
practices in proportion to the effects of those practices on 
per acre yields in a fully regulated forest over a rotation. 

The genetic planting program produces the largest impact 
during the first decade. An additional 28.4 million board feet 
in first decade annual harvest can be attributed to planting 
1,520 acres with genetically improved stock. The combined pre- 
commercial and commercial thinnings provide the next best invest- 
ment opportunity. 

Mason Bftucc a Giaaho Inc 



Mr. Robert E. Ragon 
August 20, 1982 
Page 9 



The selection of a plan alternative should consider the 
DO~22 effects of possible short falls in funding of the planned manage- 
ment practices. We have estimated that a reduction of only about 
$3 million in intensive funding after such a plan v. 
would reduce the harvest under the preferred alternative to below 
the current harvest level of 201 million B.F. However, under 
Alternative 2 such a reduction in funding would reduce the har- 
vest to about 224 million board feet or about the recent past 
level. We conclude from this that Alternative 2 is a much 
better alternative for implementation because it contains a 
base that is large enough to provide better assurance c 
timber supplies. To illustrate this we calculated the ■ 
land area (under natural growth) that would be needed to replace 
the allowable harvest lost due to lack of funds for the inten- 
sive management program. (See bottom of Exhibit 4. 
estimate that over 176,000 acres of unmanaged forest land wc 
be needed to replace the 89 million board feet harvest volume 
attributable to intensive managemei 

Cost Efficiencies for Individual Intensive Practices 

Reforestation and replanting costs on the Roseburg District 
are a substantial part of the forest management bu. have 

noted above. Our examination reveals that these arc also high 
on a per acre basis. Therefore, in terms of improving efficiency, 
this cost bears closer examination as a possible target for cost 
reduction efforts. We have reviewed planting costs for other 
agencies and industry and show the results in Exhibit 6. As a 



128 



68 23 



Mr. Robert E. Ragon 
August 20, 1982 
Page 10 



concern ovei 
cost reported in the DEIS for the Roscburg District. Foi 
two local national fori State of Oregon and forest industry, 

planting costs arc significantly lower than the Roscburg Di 
The costs reported for chemica 1 release, precommercial thinning 
and fertilization on the Roseburg District seem to be more in 
line with those of the other land managers. It should be noted 
that reforestation expenditures are made in the first few years 
of a rotation and therefore significantly affect the soil 
expectation values (SEV) shown in the DEIS. We will have more 
to say about this lat. 

Our concern here is with the need for an effort to reduce 
BLM regeneration costs. It is our recommendation that BLM should 
include in their plan provision for specific regeneration cost 
reduction efforts during the plan decade. Such reductions would 
better assure that management funding from 25 percent of receipts 
would be adequate in the future-. 

Effects and Costs of Extended Rotations 

The extended rotations used to provide for other resource 
values have a substantial impact on the allowable harvest of the 
District. We believe that BLM has not properly informed the 
DEIS public reviewers of the highly significant impact of reserving 
areas for management under extended rotations of 250 years without 
intensive management. Our calculations indicate that this manage- 
ment will use five times as much area to produce a given volume 
of annual harvest as the area needed under intensive management . 

Mason Bruce ft G.waro Inc 



Mr. i i -igon 

August 20, 1982 



In I 
needed to produce one million board ft_-el of al 
harvest under intensive managemei 

of 250 years. The capitalized annual costs of management only 
{without capital cost of the land and growing stock i 
$633,900 for the 1,018 acres of intensively managed lands and 
$450,700 for the 5,020 acres of extended rotation lands, 
indicates that the management cost of producing one million board 
feet under an extended rotation is lowest. However, one must 
evaluate the cost of the necessary extr a area of 4,002 act 
the regulated growing stock on that area. The average acre under 
a regulated condition with a 250 year rotation would contain a 
stand 125 years of age. In our opinion such lands would 
a cost value, if obtained in the Roseburg area, of at least 
$5,000 per acre. Thus, we sec that an extra capital cost of 
$20,000,000 for the extra 4,002 acres would be required in 
addition to the capitalized management cost of $450,700 in order 
to produce one million board feet annually. This illustrates 
the exorbitant cost of timber output from extended rotations. 
All possible effort should be made by BLM to use other means 
or much shorter extended rotations to provide the other resource 
values. 

Significance and Reliability of Soil 
Expectation Values in Choosing an Alternative 

The soil expectation values (SEV) contained in the DEIS 

are the result of a new analysis on the part of the BLM. We 



68 24 



Mr. Robert E. Ragon 
August 20, 1982 
Page 12 



agree that detailed economic analysis is needed to help determine 
the most efficient timber producing regime . However , we are 
concerned about the methods used and the impl ications of the 
SEV calculations. 

First of all, we have not observed the use of economic 
efficiency as a guide to planning by the BLM in past years . In 
fact, many of its management policies such as even flow of har- 
vest volume and the goal of regeneration within a 5 year period 
fail to measure up under any economic efficiency criteria . Also 
we note that the most efficient combination of management techniques 
shown in the DEIS are under a 65 year rotation for a managed 
stand, yet this was not selected. 

It seems obvious to us that SEV's were not used by BLM in 
developing the most efficient management prescription . While 
we believe these should have been used as guides, we are con- 
cerned that the BLM calculations over state costs and are not 
entirely reliable. Also, the presentation of many negative values 
is misleading. 

A major factor in determining the level of the BLM values 
is the high regeneration costs in the first years of a rotation. 
This causes most of the low or negative indicated values. In 
western Oregon millions of acres are being managed on a sustained 
yield basis which implies that other land owners/managers are 
more cost efficient, or have different outlooks for future revenues, 
or require less return on forestry investments . 



6825 



Mr. Robert E. Ragon 
August 20, 1982 

Page 1 3 

Our examination indicates the treatment of administrative 
costs by BLM in their SEV calculations was incorrect. Apparently, 
these have been handled this way because of the accounting or 
budgetary procedures used within the agency. These tend to be 
the same regardless of the alternative and thus they could have 
been excluded since the SEV's were only for comparative purposes. 

We are also concerned that a portion of the administrative 
costs are such items as planning or wildlife management. These 
produce other multiple resource values which are generally not 
to be included in the SEV calculations used to evaluate timber 
production efficiency. 

The SEV calculations should use a discount rate that reflects 
real rate of return appropriate for the federal government. The 
U. S. Forest Service recently conducted a detailed study about 
appropriate discount rates and came to the conclusion that 4 
percent was an acceptable real rate of return for government use 
in planning. We concur. 

We believe that the BLM assumptions about future price 
increases for forest products are realistic. The BLM may have 
used an initial price level that was too high. However, a lower 
initial price per MBF would not likely change the SEV's cal- 
culated because the revenues are in the distant future. 

Regarding SEV's our recommendation would be that the BLM 
reexamine their purpose and usefulness in preparing the plan 
and to limit their presentation in the EIS to only a few critical 
values as they relate to the final selection of management regimes. 



Mason Bmuct ft Gi»*wo Iwc 



129 



Mr. Robert E. Ragon 
August 20, 1982 
Page 14 



These values should be determined with a 4 

which gives greater weight to more distant values and costs, thus 

reflecting government's concern for future generations. 

We would be pleased to discuss any of our findings or 
recommendations with you or members of the Roseburg District 
staff in del i 
Sincere ly , 



Carl A. Newport 
David R. Cox / 



CAN:DRC: jlf 
Attachments 



EXHIBIT 1 
ESTIMATED SALES, HARVEST RATES AND PROJECTED REV 
ON ROSEBURG DISTRICT, BI,M 
IN FY 1984, 1985 AND 1986 



FY Year 

1981 

1982 (est.) 

1983 (est.) 

1984 (est.) 



1984 
1985 
1986 



Estimated 

Sales 

MBF 

182,900 

185,000 

200,000 

246,000 



Harvest Harvest 

Level Value 

MBF $/MBF 

150,800 $322 



Aver 
Sales Value 
5/MBF 

$259.81 

150.00 

180.00 

216.00 



Optimistic Value Level 

185,000 260 
190,000 150 
200,000 180 



O S, C 25% 

Funding From 
Estimated Ha rvest 
i on $ 

12.1 



12.025 
7.125 
9.000 



Pessimistic Value Level 



1984 

1985 
1986 



185,000 200 
190,000 130 
200,000 150 



9.250 
6.175 
7.500 



EXHIBIT 2 

COMPARISON OF FIRST DECADE 

ESTIMATED FOREST MANAGEMENT COSTS 

FOR ALTERNATIVES 2, 4 & 5 

ROSEBURG DISTRICT - BLM 



.1/ 



EXHIBIT 3 
NET PRESENT VALUE OF FUTURE REVENUES AND COSTS- 
FOR PLAN ALTERNATIVES 2, 4 AND 2 (WITHOUT INTENSIVE MANAGEMENT) 
DURING THE FIRST DECADE OF EACH PL 



Present Value Present Value 



Alternative 



Total Decade Costs- 
Total Planting and 
Replanting Costs 

Planting and Replanting 
Cost as a Percent of 
Total Costs 



$75,218,600 $70,543,400 $60,480,200 
33,820,800 31,640,600 23,883,800 



45% 45% 39% 

Sale Preparation and Admin. 33,689,400 31,477,300 35,299,200 



Sale Preparation and Admin. 

as a Percent of Total Costs 45% 



45% 



Total Cost per Thousand 
Board Feet Produced 



$28.17 $28.33 



581 



$30.10 





1st Decade 


1st Decade 


Be 


nef it/Cost 


Alternative 


Revenues 


Costs 




Ratio 




M$ 


M$ 






4 (BLM preferred) 


$491,185 


$57,981 




8.4:1 


2 


526,101 


61,824 




8.5:1 


2 w/o intensive mgmt . 


350,576 


55,162 




6.3:1 



1/ 



Revenue and costs discounted at 4 percent from the midpoint 
of the decade. Costs (those shown in DEIS on page 121) were 
increased at 0.42% and revenues at 1.65% real rates to the 
midpoint of the decade. 



- Includes costs shown in BLM, Roseburg DEIS on page 121. Costs 
are not discounted. 



130 



COST NATIVE 2 

ROSEBURG DISTRICT - BLM 



IN OP AREA 
NEEDED TO PRODI 1 
ANNUAL HARVEST UNDER INTENSIVE AND EX 
ROSEBURG DISTRICT - BLM 



visive 
: ml Ln ai t ei rial Lve 2 

Value of Increased Annual 
I During Firs! Decade due to 

Value of the Annual Costs 
t Practices 
During First Dot. 

Ratio of 1 1 

il ed ai lowable Cut El 
g First Decade For: 



89,280 MBF 



5175,525,000 



$6,662,000 



Intensive 
I ice 



Extra Acres to Extra Annual 
Annual be Treated Harvest per Cost per Acre 
Harvest During Decade Acre Treated Treated 



Planting 28.1 MMBF 

i on 19.6 MMBF 

CT 37.5 MMBF 



1,520 
57,984 
42,240 



18.490 MBF 
0.338 MBF 
0.888 MBF 



10 
72 
90 



Acres Needed to Provide One 

on Board Feet (B.F.) of 
Sustained Yield Harve 

Acres Harvested Each Year to 
Provide One Million B.F. 

Total Capitalized Cost of 
Management Expenditures to 
Produce One Million B.F. 
Indefinitely (4% Rate) 

Additional Acres Needed to 
Produce One Million Board 
Feet Under Extended Rotation 

Estimated Cost of Additional 
Land and Growing Stock Needed 
Under Extended Rotation at 
$5,000 per acre. 



ment Ro- 
Regime 



1,018 ^c. 5,020 ac. 

12.89 ac. 20.08 ac . 



$633,900 



4,002 ac. 



$20,000,000 



85, 140 MBF 



Additional Acres of Naturally 

Grown Forest Land Needed to 

Replace and Sustain the Same 

Amount of Annual Harvest (85,140 MBF) 

as is Obtained by Intensive Management 



176,400 acres 



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Response to comments in Letter 68. 

68-1 See response to comment 4-1. 

68-2 The 70,000 acres of old growth remaining under Alternative 7 after 
ten decades of management is the result, for the most part, of a 
large acreage withdrawal because of reforestation problems. The lands 
would occur as small tracts not properly distributed to provide 
habitat for the identified spotted owls. 

On the other hand, contained within the 68,100 acres of old growth 
remaining under Alternative 6 are acres specifically earmarked and 
arranged around the identified owls so as to meet their habitat 
needs. 

68-3 See response to comment 11-8. 

68-4 The Oregon Endangered Species Task force management recommendations 
and the proposed revision of the Oregon Interagency Spotted Owl 
Management Plan provided a basis for EIS analysis, not a specific 
proposal for implementation. 

68-5 The DEIS was in error. The text has been revised in the FEIS, Chapter 
3, Vegetation Conclusions section. 



131 



68-6 The Glossary definition has been corrected. 

68-7 The methodology utilized to determine elk population response to 
varying habitat conditions in the Tyee area provided for the 
classification of forest stands in excess of 120 years of age as 
survival cover. Additionally, stands 45-120 years of age were 
assumed to provide summer and winter thermal cover needs. Refer to 
DEIS, Chapter 2, Affected Environment, page 45. 

68-8 Forest stands 50-120 years of age meet thermal cover needs. Stands 

120 years of age and older supply both the food resources and thermal 
qualities viewed as important for survival during severe winter 
weather periods. The age class spread represents a range of quality 
in relation to cover, with the older stand providing better quality 
survival cover and being capable of better serving the overall needs 
of the animals. 

68-9 As stated in the EIS, Chapter 3, Table 3-11, the elk populations are 
predicted to decline 20 percent below present levels after five 
decades in response to the changes in habitat (cover- forage) brought 
about by intensive forest management practices on the habitat they 
occupy. Elk would continue to exist. Simply stated, the habitat 
quality which exists today is thought to be capable of supporting a 
larger population of elk than that which will be a product of five 
more decades of intensive forest management. 

68-10 The 18 pairs of spotted owls projected to remain in Alternatives 3 
and 4 represent a 67 percent decline from existing conditions. This 
decline in owl pairs comes as a result of reducing 



the old growth base by appro* 
relationship, it can be stated thai the ow] 
indicator of chan-j 

68-11 The text has been revised in the PEIS, Chapter "i, Impai 

Transportation System in Terrestrial Vert ' .on. 

68-12 The text has been revised in the FEIS, Chapl ts on Animals, 

Other Timber Management Treatments section, del* 
statement on slash burning. 

68-13 Western Oregon biologists have noted slash from pre-comm 

thinning lasting 1-2 decades. Approximately 30,000-40,000 acres would 
be treated in the first decade, representing about 10 percent of the 
SYU acreage and a significant loss of habitat. 

68-14 It may be that shelterwood and seed tree harvest provide adeq 
forage; however, commercial thinning as practiced in the Ro.v 
District creates neither prime forage nor cover. Compared with old 
growth habitat interspersed with clearcuts, quality of thinned areas 
as elk habitat is considerably less. 

68-15 The text has been revised in the FEIS, Chapter 3, Impacts on Animals, 
Fish Conclusions section. Temperature has been removed from the 
discussion. See response to comment 16-18 for discussion on 9 

68-16 The text has been revised in the FEIS, Chapter 3, Impacts on Animals, 
Terrestrial Vertebrates, Timber Harvest section. 



68-17 See text revision, FEIS, Appendix 3, Table B-2. 

68-18 See response to common issue 5. 

68-19 As noted on page 114 of the DEIS, an analysis of the economic 
efficiency of the forest management practices in the Original 
Proposed Action was requested by members of the public during the EIS 
scoping process. Soil expectation value was the method of evaluation 
requested. Soil expectation value is not a variable listed in either 
the original district planning criteria (Appendix C) or the O&C 
Forest Resources Policy (Appendix A) to be used in developing plans 
for BUA administered forest lands in western Oregon. 

68-20 Table B-2 has been revised to increase the number of baselines for 
forecasting revenue; however, note that the numbers reported in 
Tables 3-1 and B-2 of the DEIS are decadal averages spread evenly 
across the period for the purpose of obtaining a discounted 
benefit-cost ratio of the timber management program in the proposed 
action. No attempt was made to speculate on cyclical ups or downs. 
The 1984 to 1986 harvest level reported could be a significant 
understatement of actual harvest if the economy is in an upturn and 
the more than 616 MM bd. ft. on the district now sold but uncut were 
also being harvested. In the case of increased actual harvest, the 
number of acres being planted would also be greater than that planned 
for in Table 1-2 of the DEIS. Also, see response to comment 15-2. 



68-21 Neither the district's planning criteria (Appendix C) nor the O&C 
Forest Resources Policy (Appendix A) suggest that a choice among 
alternatives will be based on econaru 

feasibility was a factor in the selection of intensive management 
practices for all alternatives. 

68-22 See response to carutDn issue 2. 

68-23 See response to common issue 4. 

68-24 See response to comment 68-19. 

68-25 Table B-l includes interdisciplinary support arid review as a 
the district forest management program. The costs of inter- 
disciplinary support and review are in Table B-6 
DEIS. The baseline yields, costs and revenues of Table B-6 in 
DEIS are the determinates of the analysis of soil expectation value. 



69 



132 



ASSOCIATION OF O&C COUNTIES 



COWM 0*11 KHMOC* Nil 
■INTO* COUNTY COUMTNOVU 
CORVA1LI9 OftfOON »'»» 



COUU UN ' 

KM." cowwrv c 

0*1 LA* ORIOONtflM 



f^f 



August 19, 1982 



PHOHI kmtmm 

■ARROWS COUNUL 
B1 I * ISVi ftVtMJl 



Mr. Junes Hart, Disc. Mgr. 
Bureau of Land Management 
777 NW Garden Valley Bvld. 
Roseburg, OR 97470 

Dear Jim, 

On behalf of the Association of O&C Counties, the following response to the 
Roseburg District Bureau of Land Management Timber Management Draft Environmental 
Statement is here-wlth submitted. 

In the past, responses to BLM Draft Statements were intended and limited to 
their scope and adequacy. Advocacy of a particular plan was the subject of the 
response to the Final EIS . We understand that the process has now been changed 
where-by the FEIS will, in effect, become a Tentative Decision Document. Thus 
this response will not only critique the DEIS but it will also set forth our druthers. 

The DEIS appears to be adequate in scope and is sufficient in detail on most, 
but not all, Issues. Our concerns are listed and discussed in the following para- 
graphs . 

COMPARATIVE COSTS 

Nowhere in the DEIS is there a table showing the budgetary requirements of 
each Alternative. The lack of such data leaves the responcUr and the decision 
maker in the dark. Each Alternative is developed on the premise that there will 
be full funding. Past and present trends of Congress indicate that unlimited 
funds will probably not be available. Thus after a plan is selected and implemented, 
the annuaL timber sale will still have to be tailored to fit the available funds. 

We remind that the days of easy money due to the use of a generous 25% plow- 
back fund appear to be over. 25% of projected receipts during the next decade 
will not be sufficient to meet the needs of Alt. 5 (the Ejdsting), much less, monies 
needed to carry out the higher level of intensive management called for in Alt. 4, 
(the Proposed Action). 

We are not faulting the District for proposing a higher level of intensive 
management, we commend you. But the reality of full funding is Is doubtful, accord- 
ingly, the chosen plan must be responsive and flexible to the mode of each years 
Congressional monetary priority. Because of their higher timberland base. Alternatives 
I and 2 will be more adaptable i:o funding deficiencies than the other Alternatives, 
including the Proposed Action. 



Mr. James Hart 



Auguit 19, 1982 



We trust that the Pinal EIS will contain the projected cotti of each rltar- 

native . 

DEPARTURE FKOM NON-DECLININC EVEN-FLOW 

The DEIS leads one to believe that any departure that takes the allowable 
harvest below the Long Run Sustained Yield for any period of time is illegal. 
This Is not so - It Is simply Bureau policy. Historically the private timber lands 
of Douglas County have provided the lion's share of raw wood for local manufacturing. 
Only in very recent decades have the Federal tlaberlanda made any sizable contrib- 
ution to the needed supply. The result of this imbalance Is that private stands 
of harvestable timber are In short supply and their new stands of regrowth 

are a few decades from maturity. 

Table C-l shows that over one half of the BLM acreage In the .District is above 
rotation age. This over-abundance of mature timber compared to a short supply of 
growing stock is almost the exact opposite of the situation existing on the county's 
industrial private forest lands. Private growers are short on mature timber and 
long on reprod. It appears that each (private and federal) have what the other 
needs for a balanced age-class distribution. If not now, surely this possibility 
of departure should be explored prior to the next decadal planning exercise. 

CONSISTENCY WITH THE O&C ACT ANT) OTHER LAI'D USE PUNS 

The O&C Act specifically stresses the stability of local communities as a major 
purpose. The Federal Land policy and Management Act states that the land use plans 
of the .Secretary "shall be consistent with State and local plans Co the maximum 
extent that he finds consistent with Federal law and the purposes of the Act". 

The DEIS Indicates that the Proposed Action is not consistant with the Forestry 
Plan for Oregon and we submit that the larger acreages of land set aside for 
unprotected wildlife species is not in compliance with FLPMA or the O&C Act. 

FERTILIZATION 

We note that the PA provides for about 56,000 acres of chinned stands to be 
fertilized. This is a commendable start. However, we believe that among the 
_ 100,000+ acres of stands under Che 30 year class shown on Table C-l, chere is also 
Qy~^ an opportunicy for a fertilizer program on some unthinned stands. We recommend 
that these acres be surveyed to determine if such a possibility exists. If the 
survey finds, as we expect, that some unthinned stands can be benefited, the plan 
should allow for it's immediate implementation. Lost production is lost forever. 

VISUAL MANAGEMENT 

Because of the mixed ownership pattern, it is doubtful that any BLM visual 

I control will be of any meaningful value. We believe that chat the BLM's visual 
management program should be restricted CO only those areas so designated as scenic 
routes by the Federal, State or Local governments. 

In addicion where che BLM's ownership is incer-mixed with unrescricced privace 
lands, we submic chat the 250 ya minimum harvesc age Is much too high. In our 
detailed analysis of the Coos District plan, we concluded that a 120 MHA was 
sufficient. Under the Area Control Harvest concept as proposed, only 1.2% of the 
land area would be disturbed annually or 12% during the decade. 



Mr. James Hart 



August 19, 1982 



MANAGEMENT CRITERIA AND CRITERIA APPLICATION 



July 11, 1982 



This Association put forth considerable effort and resources in responding 
to the Co^s-Curry EIS . You have previously been provided with a copy of chac 
report. We are please to note that the Association' s views as set forth in that 
document mesh well with the new criteria adopted by the National Director. If 
interpreted and followed as we expect It to be, a high level of output can be expected 
without undue environmental degradation. 

SUMMARY 

(1) The highest possible level of timber production should be the goal 
consistent with applicable laws and regulations. (2) Amenities not required by law 
should be carefully blended within the the timberland base in e manner thaC does 
not unduly interfere with timber production. (3) Budget requirements of each Alt- 
ernative must be known before a decision can be made. (4) All incensive managemenc 
practices with a positive B/C should be Included regardless of which Alternative 
is selected. 

CONCLUSION 

In consideration of the above and the information within the DEIS, we believe 
that the output level of timber can be higher than that of the Proposed Action. 
Without the benefit of computer data and professional assistance, Alternative 2, 
combined with the adjustments required by the new criteria, appears to be our 
preference. We also note chat Alt. 2 reaches che regulated position in less time 
and that the period where some 50 year old stands will be harvested is shorter 
by one decade. 

Finally, we commend you and your able staff for a job well done. The DEIS 
reflects sincerity, devotion and inventiveness. We know that you will take our 
comments In the constructive light that is intended. 



Respectfully submitted 



Ray E. Doerner, Exec. Dir. 



Response to comments in Letter 69. 

69-1 Neither the district's planning criteria (Appendix C) nor the O&C 
Forest Resources Policy (Appendix A) suggest that choice among 
alternatives will be based on funding requirements. Common issue 2 
projects the district's timber sale offerings if funding were 
insufficient to meet the district's commitments to intensive 
management in Alternative 9, the Preferred Alternative. 

69-2 Generally, fertilizing unthinned stands more than 10 years prior to a 
commercial thinning entry or final harvest does not yield an economic 
return. Fertilization plans in the Preferred Alternative (Alt. 9) 
include unthinned stands which exhibit spacing characteristics of 
thinned stands. 

69-3 The Preferred Alternative includes special visual considerations for 
BLM recreation areas and State of Oregon designated scenic areas. 
Refer to DEIS, Chapter 3, page 82. Also, see response to comments 
58-2 and 58-3. 



71 




133 



Western Forest Industries Association 

1S0O S W. TAYLOR STREET • PORTLAND. ORECON 97205 

TE LEPHON E 
SO 3 - 224- 5455 

August 18, 1982 



Mr. James E. Hart, District Manager 
Roseburg District Office 
Bureau of Land Management 
777 N.W. Garden Valley Blvd. 
Roseburg, Oregon 9 74 70 

Re: Roseburg Timber Management Draft Environmental Impact Statement 

Dear Mr. Hart: 

Western Forest Industries Association (WFIA) appreciates the oppor- 
tunity to comment on the Draft Environmental Impact Statement for the 
Roseburg District Timber Management Plan and your proposed action. Our 
Association is comprised of approximately 100 manufacturers of lumber 
and plywood with mills located throughout several western states. These 
firms are primarily small, independently-owned businesses that share a 
mutual dependence on timber produced on public forest lands for a source 
of raw material. Several of our members are major purchasers of BLM 
timber in western Oregon, including the Roseburg District. Consequently, 
we have been deeply involved in reviewing the timber management proposals 
being prepared by several BLM districts. The future viability of our 
members, and the stability of the communities that are dependent on their 
operations, will be determined by the long-term productivity of public 
forest lands. 

In quite simple terms, we believe the future availability of timber 
from public lands will be determined by the amount of commercial forest 



71-1 



Mr. James E. Hart 
August 18, 1982 
Page Two 



land preserved for timber production purposes. Our goal in participating 
in your planning process is to maintain or expand the intensive timber 
production base. This goal is shared by the Oregon State Department of 
Forestry in its objectives for the Forestry Program for Oregon and by 
the House of Representatives of the Oregon State Legislature (see House 
Memorial ffl, enclosed). Unfortunately, all of the BLM proposals made 
to date are inconsistent with this goal. Your proposal is no exception. 
While timber production will increase by 48 million board feet per year 
under your proposed action, the increase in yield will occur on nearly 
44,000 fewer acres. In order to implement the alternative, significant 
increases in intensive forest management investments will be required. 
As an Association of forest industry concerns, WFIA applauds your leader- 
ship in promoting the latest scientific advancements in forestry. How- 
ever, we do not support, and in fact oppose, the use of intensive manage- 
ment investments as a vehicle to trade away productive forest land for 
unsubstantiated non-timber uses. Paramount among our many concerns is 
the outlook for revenue to finance the intensive management program you 
have proposed. Your cash flow scenario assumes future stumpage prices 
in excess of $300/MBF and that timber currently under contract will be 
harvested. In light of the less than certain future for funding intensive 
management, it would seem prudent to analyze some alternative means of 
achieving the same timber production objectives suggested in the proposed 
action. We believe the most viable option is to increase the amount of 
land allocated to intensive timber production. Such an alternative would 
most likely result in a more cost efficient method of achieving your tim- 
ber harvest goal. The major deficiencies of the Draft Environmental 
Impact Statement that lead us to this conclusion are: 

1. No analysis of the opportunity costs of re- 
moving productive forest land from the in- 
tensive timber production base. 



Mr. James E. Hart 
August 18, 1982 
Page Three 



Mr. James E. Hart 
August 18, 1982 
Page Four 



71-2 



71-3 



2. Faulty analysis of expected revenues. 

3. Inadequate cost data for implementing each of 
the alternatives. 

4. Erroneous cost efficiency analysis. 
Each of these concerns will be addressed individually. 
OPPORTUNITY COSTS 

The proposed action includes several classifications of lands placed 
in the Constrained Timber Production Base. Habitat for spotted owls, 
old growth blocks of various sizes, osprey and heron habitat, riparian 
zones and visual management areas totaling 52,047 acres will be placed 
in the constrained base and managed under area control. It is imperative 
that the opportunity foregone in terms of timber production, income to 
the Federal Treasury and the counties, and the benefits to dependent 
communities be assessed for each of these resource allocations. The 
tradeoffs involved in removing productive land for each of these non- 
timber uses can be best assessed by disclosing the opportunities fore- 
gone in this manner. The public will be in a better position to under- 
stand the relative costs and benefits of these resource allocations. 
REVENUES 

Table B-2 on page 116 of the Draft EIS displays an erroneous repre- 
sentation of expected revenues. For example, revenues expected in 1984 
are calculated by multiplying the price of stumpage ($302/MBF) by the 
proposed action harvest level of 249 million board feet. There are two 
major flaws in this prediction. First, timber sales harvested in 1984 
will be those sold in 1981 and have very different stumpage values than 
those displayed in Table B-2. Second, the volume harvested in 1984 will 



71-3 



71-4 



71-5 



more nearly reflect the sale program in effect in 1981, i.e. 201 million 
board feet. Likewise, volume harvested in 1985 will be from sales sold 
in 1982, etc. Therefore, the expected revenues displayed in Table B-2 
are overstated for 1984, 1985 and 1986. Furthermore, the stumpage rates 
forecasted for the planning period may well be optimistic. Some documenta- 
tion should be provided in the EIS. 

COST DATA BY ALTERNATIVE 

In order to perform an acceptable economic analysis of each alterna- 
tive, the cost of implementing each alternative is necessary. Table B-l 
displays the forest management costs for the proposed action but does not 
include total costs or itemized district and State overhead costs. These 
cost figures should be displayed for each alternative, along with expected 
revenues for each alternative, and discounted back to present net value. 
Data displayed in this manner will facilitate a more accurate assessment 
of the relative efficiency of each alternative. 

SOIL EXPECTATION VALUES 

Your use of soil expectation values in assessing the economic effi- 
ciency of management regimes is extremely misleading. Bare land economics 
may be useful in determining the relative efficiency of alternatives, but 
the negative values displayed in Tables B-3 through B-4 imply that the 

I management practices are not cost effective. Why you chose this method 
of analyzing management opportunities is not clear. The fact is, the 
Roseburg District has a large volume of standing inventory that is ex- 
tremely valuable. We believe it is inappropriate to ignore this value in 
calculating the costs of producing the next rotation. Specifically, re- 
forestation costs should be viewed as a cost against harvesting the exist- 
ing stand, not in establishing a future stand. Existing laws and regula- 
tions require that reforestation be assured prior to making a decision 



134 



Mr. Jan 

August 18, 1982 

Page E i 



Mr. James B. Mi r t 
August 18, 1982 
Page Six 



to h.ir to charge reforestation 
and associated costs again Lng stand rather than the future 
stand. The existing stand could not be cut without a commitment to ro- 
tation. An analysis of the man ... > ! izlng this more 
traditional approach will i more accurate assessment 

The Final Environmental Impact Statement should include Information 
to satisfy the shortcomings described above. We believe the additional 
analysis will demonstrate that the proposed action is a very risky alter- 
native relative to funding, will result in tremendous opportunity costs 
in terms of intensive timber base reductions, and may we] cost 

efficient than some alternative land base/Intensive management mix. 

RECOMMENDATIONS 

We ask that an alternative with a land use allocation similar to 
Alternative #2 be given consideration as the proposed action. Such an 
alternative would strike a compromise between current land uses and those 
suggested in the current proposed action. Of greatest significance, an 
intensive timber production base of approximately 300,000 acres would not 
be as sensitive to budget short-falls as the current proposal. In case 
of funding shortages, subsequent reductions in timber harvest would not 

My as significant. In addition, the benefit/cost relationship 
would be more favorable since it would require a smaller investment in 
intensive management to yield the same, if not higher, harvest level. 

Our recommended alternative would also be consistent with the 
Director's July 15, 1982, Criteria for Application of & C Forest Policy. 
The current proposed action is not. Specifically, compliance with 
Criteria "5 would be better accommodated by Alternative #2 in regard to 



the allocation of commercial foi 

native would also maintain future options for preserving old growth tim- 
ber stands. At the end of the planning period, over 70,000 acre* of old 
growth timber would remain on the district 

acres of old growth would remain; more than enough to sustain a 
population of spotted owls. 

When all the major criteria arc considered; I ncy of local 

communities on the timber resource, the goals of I , irtment of 

Forestry, House Memorial #1, the Director's Criteria for Application of 
& C Forest Policy, the tremendous cost of the proposed action, the un- 
certain outlook for funding intensive management practices, the cost/ 
benefit relationship of the proposed program, and the over abundance of 
old growth timber, Alternative 02 Is the most prudent and logical choice 
for final adoption. 

Very truly yours, 

WESTERN FOREST INDUSTRIES ASSOCIATION 



, 1H 



Mr. William Leavell 
Mr. Robert Burford 



Jj£( Gelslnger /J 



ORECONLECISI VTIV 



House Memorial 1 



c ichucm ol Represents 



The following lurtunury is ™.i pn . 

!■■, ti,,- I egislative Assembly, li 
ininduont. 

Urges I niled Slates Bureau 



and Ho 



I.. ihu Honorable 

assembled 

Wc, youi memorialists, tra House ol Represents 
assembled most respectful!) request il 
Management kind use planning in Oregon and specifically 

Whin-. in umber management proposal 
preparation in all Bureau of Land Managcm 



Hoi si Ml. MORI VI i 
f Representatives i>( ihe United State* of America, 



..l the State of Oregon, in legislative session 
, to intervene in the Bureau of Land 
in < 'oos B.iv district because 
being developed in the Coos B.iy district and in plans under 
districts in western Oregon; and 
Whereas the limbei manag. n ! ' - ,nd Management's Coos Bay d.smci 

k vul bj Id million board feci, eliminate over -00 jobs in the 
local area and reduce count) limbei revenues by 2 t million dollars; and 

Whereas the pni ihe prop«>sed reduc 

reduce the intensive umber production base b] 



i> I he Bureau of Land Management's decision to 
HI acres lor the exclusive benefit of wildlife and 



■.iheiK 






and 



-natives have been developed < 

icd yield ■ • 



ol Land Managcmenl thai would allow , 

v jobs in one of the most depressed areas 



Whereas the revesting Act of Or. Bay Wagon Road Grant l^nds (43 

: • lal that governs management ol mosi Burv; md Managcmenl lands in western Oregon specifics 

I " n,K ««M»reo( 

dependent communities, .md 

Whereas the Oregon economy is dependent or, I sting and processing of renewable timber 

anil 

Whereas other Bureau of Land Management districts in western Oregon are following the precedent set by 
[he t oos Bay district by proposing reductions in the Immci production land base for nontimber uses al the 
expense of limber supply, employment ai m of dependent communities; now. therefore. 

Ik ll Resolved b) the Housf uf Reprwrnlutnes ol the Stall »l i irego" 



(1) Wc urge the Congress of Hi United States to reqi 
priority to the following goals in i. a king final decisions 

Kcemphawc the importance of ^immunity stabilily. 
individual planning districts, and make certain evt 



1 iii. i Hie Bureau <•( LmJ Managcmenl give highesl 

lht i ik» He district and olher western districts 

oil and 'a* base within Oregon and its 

y possible effori is made lo preserve the intensive 



land Kisc lor umber production purposes 

lonal shall be transmitted to each mcmhci "i the Oregon Congressional Delegation 
to e.iJi ol Hs Oregon district offices for inclusion ii 



manage 

(2) A copy of this 
lo (he Director of the Bureau of 1 .md Management 
the hearings on each district land use plan 



ft; 
ft 



74 



Response to comments in Letter 71. 



71-1 See response to common issue 2. 



71-2 See response to common issue 4. 




United States Department of the Interior 

MSII AND WII IH 1H SERVIC'l 

Portland I 
Reference: ES V/l N. 

Portland, 



135 



71-3 See response to comment 68-20. 



71-4 Table B-l in the FEIS includes cost data for Alternatives 4 and 9. 
Also, see response to comment 68-21. 



71-5 See response to comment 68-19. 



74-1| 



74-2 



74-3 



To: Roseburg District Manager, Bureau of Land Management 
Roseburg, Oregon 

From; Field Supervisor, Oivision of 
Portland, Oregon 

Subject: Review of the Roseburg Timber Management Graft Enviroi 
Statement, Douglas County, On 

We have reviewed the subject draft environmental statement on I 
Timber Management proposal and provide the following comments: 

General Comments 

Based on the information submitted, the proposed management plan could \\^h 

a significant adverse impact on area fish and wildlife resource',. 

document does not discuss impacts associated with the preferred alten 

in conjunction with anadromous and resident fish. In addition, 

concerning the displacement of wildlife through habitat reduc' i 

more detailed in the final document. It is also unclear whether wetland 

areas within the management unit will be affected. 

It is our belief that proper guidelines and selected mitigative me a- i 
should be coordinated with any comprehensive plan that you subsequently 
adopt. The final document should also consider all practicable means and 
measures that could best satisfy identified needs while at the same t 
protecting, preserving, and enhancing the quality of the environment, 
restoring environmental quality previously lost, and minimizing and 
mitigating unavoidable adverse effects. We dre especially concerned about 
maintaining a reasonable riparian buffer strip in association with each 
stream corridor. Also, bank protection is important in helping to reduce 
potential sedimentation and temperature increases. 

Specific Comments : 

page 5, para 2 . There is no discussion concerning the adverse impacts the 
proposed management would have on the fish population in the area. 
Additional data should be provided in the final statement. 



I page 24-25, table 1-5 . The "summary of impacts" table does not reflect any 
impacts on fish or their associated habitat. This catagory should be 
included. 

-i page 45, para 2 . There is no indication what portion of the existing 
74"4l riparian habitat will be altered. This should be addressed in the final 
document. 

i page 66, para 4 . Discussion of Impacts on riparian habitats and streams by 
erosion, landslides, nutrient depletion and road construction should be 
expanded and presented in more detail in the final document. Mitigative 
_- £tl measures should be implemented to prevent any long term adverse 
7*r'"v| environmental impacts. 

page 77, para 6 A number of factors which can adversely affect fish are 
presented, however, the amount of impact the various alternatives would 
have has not been discussed. 

pages 77-78 . The harvesting of timber does have an adverse impact on fish 
habitat by removing the riparian zone, changing water yields and increasing 
the sedimentation. Therefore, these areas should be quantified as much as 
possible and included in the final document. 

We appreciate having had the opportunity to review this draft. Please feel 
free to contact us if you have any questions concerning our comments. 
We would also appreciate receiving a copy of the final statement when it 
becomes avai lable. 



74-7 



I^J^dJ^^r^ 



Russel 1 D. Peterson 



Response to comments in Letter 74. 

74-1 Wetland areas are included as riparian habitats and thus would be 
affected by each alternative as described in the DEIS- Chapter 3, 
Impacts on Animals, page 75. It should be noted that the percent of 
riparian habitat associated with wetlands is quite small on BLM lands 
within the EIS area. 

74-2 See response to comment 5-3. 

74-3 Impacts are described in Chapter 3 of the EIS. Because the ai 
in Chapter 3 concluded the impacts on fish populations would 
significant, those impacts are not listed in the summar 
Chapter 1. 

74-4 Refer to EIS Chapter 3, Vegetation Section and Appendix C f Table C-4, 
for discussion on the impacts to riparian areas from each 
alternative. 



74-5 See response to comments 5-3 and 74-4- as indicated on page 26 of the 
DEIS, additional environmental assessment of timber sales will 
address riparian habitat, erosion, landslides and road construction. 

74-6 See response to comment 5-3. 



74-7 See response to comment 74-3. 



78 



136 



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/ "^ *~57 / ^ "* •'-■^- / £ ^ j -^^' -^z^t-c dJ&^.£_ 



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a i 






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78-1 







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£>K~1 — 



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17 




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~~£Z^. a~^£ ^K^ &> Z*^?-^ ^.~JL*<!U 



78-2 



78-3 



78-4 










£■****. <£L«^£^, , 



- 



&n-£~*^ ^Z£& £-C 






S~^7.9s- U^ jut£t 



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s-. J±^*£ 7>&- ~&&~ — 
if-7^ tft£- A«^" ^-*^) -^"^ c^p<^U^ 



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137 



Response to comments in Letter 78. 



78-4 







*#-&£ £>. t^^rU-LO^ 



78-1 See response to comment 12-1. 

78-2 Table B-2 has been revised to increase the number of baselines for 
forecasting revenue. 

78-3 See response to common issue 5 . 

78-4 The existence of "surplus inventory" is closely linked to both actual 
and potential harvest, as described in the DEIS, Appendix C, page 
127. The lack of surplus inventory for the Roseburg District is 
partly due to the high level of intensive management practices 
scheduled. 



80 




"Monte Montgome 
President 



Auqust 20, 1982 



James E. Hart 

District Manager 

BLM Roseburg District Office 

777 NW Garden Valley Blvd. 

Roseburg, Or 97470 

Dear Mr. Hart: 

Associated Oregon Loggers (AOL) is submitting the attached analy- 
sis of the Roseburg District draft environmental impact statement 
(DEIS) , in response to your request for comments . We enthusiast i- 
cally support the District's obvious commitment to increase 
timber supply, jobs and county revenues. AOL has maintained its 
commitment to long range forest planning, despite the current 
economic crisis, and we applaud the District' s efforts to plan 
for a future where once again there is a healthy demand for 
Oregon's forest products. 

Since the State Director has advised the Roseburg District that 
the proposed action must be amended to conform with new policy 
d irect ion, AOL will withhold its final support of an alternative 
until we have the oppor tuni ty to review the new proposed action. 
We do believe, however, that Alternative 2 provides a good foun- 
dation for the new proposed action . 



As was suggested by Bob Alver 
comments in the attached anal 
DEIS to meet laws and regulat 
does not comply with several 
tions (Subpart 1601) , related 
State goals, wildlife habitat 
implementation. AOL also bel 
not comply with the & C Act 
dations for improving the DEI 
impact statement (FEIS) into 
tions. 



ts, your planning coordinator , our 
ysis focus on the adequacy of the 
ions. AOL believes that the DEIS 
sections of the BLM planning regula- 
to process papers, consistency with 
, economic and budget analysis, plan 
ieves that the proposed action does 

AOL makes a number of recommen- 
S to brinq the final environmental 
compliance with laws and regula- 



We look forward to continued involvement in your planning 
process. 




Sue 
Pores 



Executive Committee 

Dan Pugate 

Bob Birkenfeld 

F. F. (Monte) Montgomery 

Bob Lindsay AFF|RMAT|V£ ACT|0N _ EQUAL OPPORTUNITY EMPLOYER 



ASSOCIATED OREGON LOGGERS ANALYSIS 

OF THE BLM ROSEBURG DISTRICT 

DRAFT ENVIRONMENTAL 

IMPACT STATEMENT (DEIS) 



The discussion below addresses six areas of the DEIS, which AOL 
believes are inadequate to meet BLM laws and planning regula- 
tions. 



& C ACT 

The Solic 
concluded 
dominant 
states th 
can best 
In the ca 
will occu 
has analy 
each Act 
signif ica 



itor General's opinion, dated 

that the O 6 C Act mandates 
use on BLM managed O & C land 
at "the Bureau must see how w 
be achieved on land not avail 
se of those areas of land whe 
r, the Bureau may choose one 
zed its choice in the context 
and is satisfied that the par 
ntly encroached upon the over 



September 8, 1981, 
forest production as the 
s. The opinion further 

ldlife protection goals 
able for timber production. 
re direct conflict in use 
over the other provided it 

of the principle goals of 
ticular choice has not 
all effect of these goals." 



This direction from the Solicitor General implies that the BLM 
must prepare a well documented analysis or process paper which: 

1. Assesses the location, quality and quantity 
of wildlife habitat; 

2. Defines adequate protection for wildlife habitat; 

3. Distinquishes between & C lands, and public 
domain lands; 

4. Locates wildlife habitats, for each alternative, 

on & C lands not available for timber production; 
and, 

5. Documents the economic and social consequences of 
allocating O s C lands to wildlife habitat, if this 
allocation is necessary. 

Although, this opinion has been in circulation for over a year 
now, and the Roseburg District states that they did an analysis 
of how to meet wildlife habitat concerns on non-productive & C 
lands, there is non process paper documenting compliance with the 
& C Act as Solicitor's opinion. Section 1601.7-1, of the BLM 
planning regulations, states that: 



138 



10-1 



"Records pertaininq to the analysis and 
conclusions reached by the Ditrict Manager 
and staff throuqhout the planning and 
environmental analysis process shall be maintained. 
...Such records shall be kept filed together 
and shall be available on request for public 
review. " 

*A0L recommends that a proposed action be developed, which 
complies with the & C Act and Solicitor's opinion. 

*A0L recommends that the final environmental impact statement 
(FEIS) include a process paper which documents the allocation of 
6 C lands to timber production and wildlife habitat. This 
information is of critical public concern, especially with the 
new Washington and State office direction on this issue. 



FORESTRY PROGRAM FOR OREGON 



ntenance of the commercial forest land 
e level, is of great concern to AOL. We 
all alternaties, except #1 and #5, are 
of Forestry objective regarding main- 
Section 1601.4 (c) (1), of the BLM 
ates that resource management plans will 
sible with existing officially adopted 
lated policies, plans or programs 

The proposed action reduces the land 
1.6%). AOL believes that the BLM has not 
tion to comply with Section 1601.4 (c) 



As we discuss below, mai 
(CFL) base at a resonabl 
noted in Table 1-7 that 
inconsistent with Board 
tenance of the CFL base 
planning regulations, st 
be "as consistent as pos 
and approved resource re 
of... state agencies 
base by 43,779 acres (-1 
designed the proposed ac 
{1) as required. 

*AOL recommends that the FEIS reconsider the size of the commer- 
cial forest base in each of its alternatives. The planning 
regulations, we believe, call for at least minimal consistency 
with the state's land base objective. The BLM must increase the 
size of the proposed actions commercial forest land base in order 
to comply with 1601.4 (c) (1). 

WILDLIFE HABITAT 

Over 52,000 acres of the Roseburg District have been allocated to 
wildlife habitat or visual management areas. At the end of the 
10th decade of the projection, 18 owls are expected using the 300 
acre management assumption, while no owls are expected using the 
1,000 acre assumption. Futhermore, it is projected that a 
"medium" amount of degradation of scenic quality, will occur. 



Section 1601.5-4 (a) (9) of the BLM planning regulations, which 
describes the analysis of the management situation process, states 
that: 

"The District manager shall analyze the management 
situation to determine the capability of the public 
land resources to respond to: Needs, concerns and 
opportunities identified through public 
partlciation. . . " 

This section further states that critical threshold levels should 
be considered during the formulation of plan alternate 

*AOL recommends that in order to fully comply with these regula- 
tions, the BLM should conduct a trade-off analysis of the 55,047 
QQ.2 constrained acres to document the effects (in terms of allowable 
harvest and budget requirements) of incrementally adding these 
acres back into the intensive timber management base. The BLM 

I should further provide a listing of spotted owl pairs by decade 
for ech alternative. This should include the amount of habitats 
under both the 300 acre and 1,000 acre assumption. 

ECONOMIC AND BUDGET ANALYSIS 

The BLM conducted several economic and budget analyses, on the 
proposed action for the Roseburg District, as requested by the public. 

Section 1601.5-2 (a), of the BLM planning regulations, defines 
the purpose and use of planning criteria. 

"Planning criteria shall be used to evaluate 
alternatives and to select one alternative to 
serve as the proposed resource management plan." 

One of the criteria developed for the Roseburg District states 
that: 

"Each alternative was evaluated according to the 
degree to which it would. . .provide for a high level 
of contribution to local public revenues from 
resources and activities available on public lands." 

Since economic and budgetary analysis where conducted, only on 

the proposed action and Alternative 3 it is difficult to 

understand how the BLM used the above criterion to select the 
proposed action. 

-3- 



J04 



*A0L recommends that an economic and budget analysis be conducted 
foe each alternative. Only in this way can the "revenue" cri- 
teria be properly used to select the proposed action, which will 
not only provide a high level of contribution to local and public 
revenues, but will also have a budget that is fundable. 

PLAN IMPLEMENTATION 

The proposed action reduces the commercial forest land base by 
43,779 acres (-11.6%) and increases the constrained land base by 
38,161 acres (+73.3%). Precommercial thinning acres are 
increased 28,429 acres (+230%), fertilization is increased 56,02^ 
acres (+100%), site preparation is increased 23,723 acres 
(+30%), and planting is increased is, 795 acres (+30%). Finally, 
the required budget for the forest management and development 
would increase from 50.7 to 83.8 million (Table B-7) dollars in 
decade 1, a 65% increase. 

From these figures, it is apparent that the District has huilt a 
very costly proposed action in order to accomodate multiple uses 
of the forest resource. In order to increase the allowable cut 
level, on a reduced land base, a costly array of intensive manage- 
ment practices has been proposed by the BLM. Since the BLM now 
obtains its funding for forest management by congressional 
appropriation, the huge budget requirement of the proposed action 
(a 65% increase from the present budget) may not be able to be 
completely funded. 

If the Roseburg District does not receive full funding for the 
proposed action, then the level of intensive management scheduled 
cannot be achieved and the annual allowable harvest level must 
be reduced. Certainly the most cost effective way to raise har- 
vest levels it to maintain the number of commercial forest land 
acres allocated to intensive management. Smaller quantities of 
costly intensive management practices could be utilized on a 
larger land base to reach the same allowable cut level. 

*AOL supports the choice of implementable plans and the main- 
tenance of the commercial forest land base at a reasonable level. 
The proposed action is not acceptable because of its reduced land 
base and high budget requirements, which hinder its ability to be 
implemented. Development and approval of unimplementable plans 
certainly violates Section 1601.0-2, of the BLM planning regula- 
tions, which states that the objective, of Subpart 1601, is to 
"improve resource management decisions on public lands..." 

-4- 



Response to comments in Letter 80. 

80-1 BLM planning regulations became effective September 6, 1979. The 

December 3, 1979 Federal Register included a display of BLM planning 
efforts underway on that date. Roseburg District was shown as a 
Category C, district-wide Management Framework Plan revision to which 
the new regulations were only partially applicable. Although 
regulation 1601.7-1 is applicable to the Management Framework Plan, 
through the development of a preferred alternative, it does not apply 
to the Timber Management EIS. 

The preferred alternative and other alternatives considered have been 
presented in a summary brochure prepared in September 1981, which 
indicates land use allocations applicable to EIS Alternatives 1, 4, 6 
and 8. Refer to DEIS, Appendix C, Tables C-2, C-3, and C-4 for 
allocations by alternative. Analysis in the FEIS includes Alternative 
9, which is based on the new C*C Forest Resources Policy (Appendix 
A). 

80-2 See response to common issue 4. 

80-3 The entire 43 CFR 1601.5-4 regulation section is not required for any 
transition period Management Framework Plan. Also, see response to 
comment 11-8. 

80-4 See response to comments 68-19, 68-21 and 69-1. 



83 




139 



nORTH WEST TimBER RSSOCMTIOII 



13S6 OAK STREET 
TELEPHONE 15031 



PO BOX 5554 
6869603 



EUGENE OREGON 9)405 



August 20, 1982 



Mr. James Hart 

District Manager 

Bureau of Land Management 

777 NW Garden Valley Blvd. 

Roseburg, OR 97470 

Oear Mr. Hart: 

On behalf of North West Timber Association I am pleased to comment on the Draft 
EIS for the District's new Timber Management Plan. Our Association consists of 
small independently owned lumber and plywood manufacturers in western Oregon 
and southwestern Washington, including several firms which purchase timber 
directly from the Roseburg District. Our members are almost exclusively 
dependent on federal land for their timber supply thus making the decision for 
the Roseburg District critical to the survival of the firms and the economic 
stability of the communities in which we operate. 

We have been deeply involved in the planning activities of all the western 
Oregon districts and are pleased that the content of your EIS has recognized 
many of the problems that appeared in earlier efforts. Bureau of Land Manage- 
ment planning is a complex and difficult task. In all fairness, we compliment 
you, as well as the District and State staffs, on the open and professional 
manner in which you have conducted the planning effort and attempted to accom- 
modate the many publics interested in your planning. 

At the outset we believe it is essential that the time frame of the planning 
decision and its relationship to current economic conditions be put in perspective. 
The new plan will be long term in that it considers effects of continuing the 
plan for many decades. However, in reality, it is relatively short term in that 
it will have an operational life of approximately one decade after which adjust- 
ments will be made in a new plan to reflect changing information and conditions. 
We are currently in the worst economic recession the local industry has ever 
seen and most- -if not al l--operations in the county are struggling with the very 
basis of survival. Clearly this has temporarily affected the demand and value 
of stumpage and it may be several years before conditions return to "normal". 
We as an Industry are optimistic, however, that a turn around will occur and 
that timber supply will return as the major controlling factor in the health 
of our Industry and local economy. When this will occur cannot be predicted, 
but when the new plan is implemented in 1984 we should be on our way. 



Mr. James Hart 



83-1 



August 20, 1932 



The remainder of our comments will fall into three general categories: I) The 
Planning Process; II) Adequacy of the EIS; and III) Identification of a 
Proposed Action. 

I) THE PLANNING PROCESS 

Since the outset of the planning process a concern has existed over the fact 
that the BLM's procedures did not provide for a change in the "Proposed Action" 
(PA) between the Draft and Final EIS. This seems to have changed in recent 
months since the Salem District indicated they would consider changing the PA 
between the Draft and Final EIS. Furthermore, the July 15, 1982, Criteria for 
Application of 8 C Forest Policy from Director Bob Burford directs that the 
new criteria be utilized in the Roseburg EIS process. 

It is clear, from discussions with the District staff, that how this will be 
implemented is still a matter of debate to be addressed in analysis of input 
to the draft. One of the purposes of an EIS and its public review is to focus 
on a proper decision. Changes from the current PA in the final decision will 
be necessitated by the Director's criteria. Therefore, it seems only logical 
that the process be facilitated by a change in the alternative identified as 
the PA in the Final EIS. This will not, however, require that the PA in the 
Final EIS be the implemented decision since the draft decision process remains 
intact. 

Contrary to State memorandum OR-82-601 , it is our suggestion that the planning 
team attempt to identify, from the existing alternatives, the one which best 
meets the directive on & C criteria, other laws and decision criteria and 
identify it as the PA in the Final EIS. Each alternative should then be 
analyzed as to how well it conforms. The EIS will then point out changes that 
may be needed in the remaining step of identifying the final decision. There 
is no reason that this cannot be most efficiently accomplished with a short 
form Final EIS. 

II) ADEQUACY OF THE EIS 

One of the main purposes of public review of a Draft EIS is to identify areas 
where the statement may be inadequate. We feel that additional analysis is 
needed in a number of areas. 

A) LAND BASE TRADE OFFS . The reduced timber production from the constrained 
timber production base represents some opportunity cost in terms of timber 
production foregone. While a comparison between alternatives shows the over-all 
effect and estimates can be made on an average per area production basis, specific 

I effects by land allocations are not isolated. We believe that the harvest 
contribution foregone compared to full intensive management for each special 
land classification, as identified on page 124, should be shown. A display 
similar to what is needed can be found on page B-3 of the Eastside Salem Draft EIS. 

B) BUDGET ANALYSIS . The EIS deals not just with environmental effects, but 
also with economic impacts. Since the harvest level will vary with the amount 

of funding that is available this will have a critical effect on local economics. 



Mr. James Hart 



August 20, 1982 



Mr. James Hart 



August 20, 1982 



83-2 



83-3 



On page 64 of the EIS it states, "A basic assumption of the analysis is that 
sufficient funding and personnel will be available for implementation of the 
final decision." We feel that this is an extremely weak assumption which 
deserves attention in the Final EIS. Blind acceptance of this assumption can 
lead the reader into a false feeling of security. Our concern is particularly 
heightened when one notes that the projected annual costs of intensive management 
for the proposed action (page 116) of $8,411 million is an increase of 42 percent 
over the current program of $5 - 9 million; and further, that these figures do not 
include either District or State Office administrative overhead which runs 
several million dollars per year. While the long run projections appear 
favorable, we are particularly concerned with the reliability of the assumption 
in the first few years of the program. Economically efficient harvest increases 
will be especially important as we work our way out of the current economic 
conditions. The recent reduction in the annual sale programs at Medford and 
other districts due to budget constraints indicates the reality of our concern. 

While the BLM cannot be expected to forecast the willingness of Congress to 
approve budgets, we do believe that the decision makers and the public should 
know the relative cost and risk of various alternatives. Therefore, we request 
that the Final EIS display--for each al ternative--the following information: 

1) The average annual cost of the intensive management program during the 
first decade with the cost isolated as shown for the PA on page 116, 
table B-l. 

2) The administrative and overhead costs, including an appropriate share 
of State Office costs, such that when added to number 1) above, it 
will show the total cost of operating the district. 

3} The "current situation" values for items 1) and 2) above. 

4) An analysis which would show the sensitivity of the alternative to 
fluctuations in budget levels. This would basically begin at the 
Q3— 4 harvest level proposed for each alternative and display what the 

harvest level would be at reduced budgets, in five percent increments, 
until the levels reach what you would consider the minimum that could 
be expected. 

C) THE SPOTTED OWL . When the EIS states that Northern Spotted Owl "...is 
dependent on old-growth, closed-canopy forests..." (page 78) it reflects the 
attitude that has polarized an important issue. For several years Industry has 
been urging the BLM and other federal agencies to seek out more economically 
efficient management strategies for providing for the owl. Instead, the agency 
has continued to accept without question the opinions of the Spotted Owl 
Committee which continues to base its views only on what the owl appears to use 
or prefer--not what it needs to survive. 

Even though the Director's criteria clearly established the BLM's policy regarding 
the owl on & C acres, this has not reduced Industry's concern for the bird. 
As was pointed out by the Fish and Wildlife Service in their January 1982, 



83-5 



Status Review, the species is not Threatened or Endangered. Due to vast acres 
of mature and old growth on the District it is clear that opportunity to protect 
the owl without reductions in timber harvest levels exists on the Roseburg 
District. The Draft EIS fails to recognize this fact, instead it indicates that 
the owl may disappear completely in one hundred years and states, "...it is not 
possible to predict when various pairs would have their habitat removed." 
This dooms-day, hide-your-head-in-the-sand approach must be corrected in the 
Final EIS. 

During the scoping process on the District, I requested that the BLM analyze 
the opportunity to maintain the owl habitats through each of the first several 
decades of the planning horizon. This request was not met. However, I believe 
it is extremely important for the public to see and understand the results of 
such an analysis. We again request that it be included in the Final EIS. The 
Final EIS should contain an array which, beginning with current owl populations, 
shows for each alternative and each decade the number of 300-acre habitats and 
pairs of owls that can be maintained to the end of each decade. This should 
be carried through at least the first four decades and should not contain 
replacement stands. It should not be necessary to analyze the 1 ,000-acre core 
concept since the letter transmitting the proposed revision of the Spotted Owl 
Management Plan indicated little confidence in this figure and only asked that 
such allocation be maintained for a period of five years. Clearly, during the 
first decade of the plan the District population will not drop below viable 
population levels even if no attention is given to the owl. While the development 
of this array will require many "best estimates" this should not be a serious 
concern considering that most of the spotted owl policies today, and many of the 
outputs for other resources shown in the EIS, are indeed little more than best 
estimates by the various specialists. The basic assumption that must be used 
in developing the array is that the BLM would schedule harvest units in a manner 
that will maintain the greatest number of habitats for the longest possible time. 

The analysis is very important because it will give the public a more realistic 
view of the spotted owl issue and will provide some idea as to how much time we 
have to complete our research and study. 

Another important addition to the EIS should be to discuss and describe the owl 
and old-growth research that is planned for the next decade including what will 
be done by the BLM and other agencies; and exactly what type of information 
will become available. 

When the Preferred Land Use Alternative was presented to the public for comment 
in September 1981, an important concept was presented and contained in the 
statement on page 23: 

During the planning period (the next decade) there will be minimal impact 
on habitats of the Roseburg District. 

IThe discussion then pointed out that it would be four to five decades before 
the impacts might become critical. This whole discussion was eliminated from 
the Draft EIS. To those of us in the public looking for rational solutions 



83-6 



140 



Mr. James Hart 



August 20, 1982 



Mr. James Hart 



August 20, 1982 



83-8 



839 



83-10 



to the problem of wildlife conflicts, the exclusion was unfortunate. It is 
a common misconception by the public that some species of wildlife are about 
to be wiped out in the District. The BLM must take the responsibility of 
demonstrating that the fears are unfounded and that reasonable wildlife manage- 
ment policy is part of the Bureau's activities. 

D) AREAS OF CRITICAL ENVIRON ME NTAL CONCERN (ACEC's) , The EIS is inadequate 
scussion of ACEC's Fal Areas (RNA's). More complete 

descriptions of the areas, why they are considered, and the decision criteria 
that will be used should be presented. Before any designation is final it should 
be demonstrated that such allocations are justified and the planned management 
explained. In the case of RNA's it should be shown that the proposed areas are 
the best candidates available in the state for the particular ecological unit 
being protected. 

E) WILD AND SCENIC RIVERS (page 27). The Final EIS should indicate which 
rivers in the District have been included in the National Park Service Inventory, 
the rating assigned in the Inventory, and how long the inclusion in the Inventory 
is expected to restrict management. 

F) FORESTRY P LAN FO R OREGON . The analysis of alternatives in terms of 
compliance with the goals of the Forestry Plan for Oregon needs to be expanded, 
especially since compliance is a criteria identified by the Director. The 
analysis should not simply group the alternatives into classes of consistency 
as in table 1-7, but should rank each alternative from most consistent to least 
consistent. Where possible the analysis should deal with quantified output 
values to demonstrate the level of consistency. 

Another important indication of the policy of the State of Oregon regarding the 
management of the S C lands is House Memorial Number One, which was passed 
„. ...a |in the last regular session of the Oregon Legislature. The Final EIS should 
Oo'll |present the Memorial and indicate the degree of compliance of each alternative. 

G) FACT VERSUS OPIN ION. There are a number of discussions within the EIS 
which appear to be oriented at promoting particular viewpoints about the manage- 
ment of the BLM lands that are contrary to the mandates of the & C Act. These 
discussions utilize "buzz" words and technical jargon that sounds impressive to 
the general public, but actually contribute little to the value of the EIS. 
Examples are the discussions of old-growth and forest productivity on page 42 
and ecosystem management on page 71. The statement that the symbiotic relation- 
ships in old-growth stands "...may prove critical to long term timber production., 
is clearly a less than professionally accepted opinion. These discussions 

also failed to draw the important distinction between forest productivity in 
natural stands and productivity in managed stands. 

H) NON-TIMBER BASE OUTPUTS . A major short-coming of the Draft EIS is that it 
tends to deal just with that portion of the District which meets the TPCC 

1 criteria for intensive management. Non-timber outputs from the withdrawn lands 
are extremely important to the public and should be fully discussed and displayed 
in the EIS. 



I) DEPARTURES . We are pleased that a discussion of departure alternatives 
was included in response to our proposal. While the review was incomplete 
it did indicate that opportunities to meet social needs may exist beyond the 
rigid even-flow concept while still meeting the basic values of sustained yield 
management. 

Ill) IDENTIFICATION OF A PROPOSED ACTION 

As discussed earlier it is desirable, if not required, that the proposed action 
be changed in the Final EIS. Since further adjustments will be possible in the 
decision process if the analysis indicates they are needed, we can see no reason 
for the BLM to attempt to generate any new alternatives. Rather, our review 
indicates that Alternative 2 will meet the requirements of the law and the 
criteria for management of the western Oregon BLM lands as set out by the 
Director. Alternative 2 should be identified as the Proposed Action for evaluation 
in the Final EIS. 

Let us look at some of the key criteria embodied in the 4 C Act and management 
criteria in relationship to the outputs indicated for Alternative 2. The 
Director set out the policy in seven specific criteria: 

Criteron 1 ) Provide an optimum and non-declining yield of wood products to 
enhance the economic stability of local communities and industries while 
providing for other forest values as required by law. Optimum is defined as 
approaching, meeting, or exceeding the State Forestry Plan for Oregon goals. 

Alternative 2 does not fully meet this criterion in that the land base and harvest 
levels are less than Alternative 1, which conforms with the Forestry Plan goals. 
However, in order to meet the other criteria Alternative 2 would appear reasonably 
optimum. 

Criteria 2 and 3 ) Limit or exclude timber production to protect "...high 
public recreational value..." at outstanding sites and "...protect and maintain 
scenic quality in areas of important visual value " 

Alternative 2 meets these criteria with the allocation of 8,383 acres to visual 
management and 1,185 acres for recreation management. This provides assurance 
that key resource areas such as the North Umpqua Corridor are protected. 

Criterion 4 ) Maintaining water quality at federal and state standards by 
incorporating mitigating measures in forest management. 

Alternative 2 clearly will exceed this criteron with, in addition to mitigation, 
the assignment of over 18,000 acres to the constrained timber base for riparian 
zone management. 

Criterion 5) Management of non-timber forest values. The criteron provides 

for allocations, after analysis of effects; for the protection of wetlands-- 

including riparian zones--and providing habitat for Threatened and Endangered 
species. 



Mr. James Hart 



August 20, 1982 



Response to ocmments in Letter 83. 



Alternative 2 provides for non-timber values. The 38,530 acres of the District 
withdrawn from the intensive timber base and the 24,786 acres under constrained 
management certainly meet the requirements. Over 6,000 acres are provided to 
protect the bald eagle, osprey, and heron habitat. 

Criterion 6 ) This criterion deals with additional allocation of commercial 
forestland. It prohibits allocations "...unless such action is found necessary 
to protect future options for maintenance of serai stage distribution assuring 
continued high timber productivity." 

Alternative 2 clearly protects future options since over 140,000 acres of mature 
and old growth will remain on the District at the end of the planning period; 
thus, no such allocations are necessary . It may be desirable to set out some 
harvest scheduling constraints for the first decade to assure that a proper 
cross-section of desirable units is maintained through the decade, but this 
would not require withdrawal from the harvest calculation base. 

Criterion 7 ) This criterion urges maximum use of intensive management practices 
to the degree feasible and within economic efficiency measures. 

The effect of this criterion will be shown from further analysis. The practices 
with Alternative 2 meet this criterion as well--if not better--than the other 
alternatives. 

In conclusion, we believe the next step in the planning process should be to 
identify Alternative 2 as the proposed action in the Final EIS. The analysis 
of this alternative and application of criteria to all alternatives in the 
review will then indicate what changes may be needed in making a final decision. 

Sincerely yours, 



^'L^i-CvtviA^y /*ra<pijztA4>{ 



Dennis Hayward 
Field Forester 



83-1 See response to ccmmon issue 4. 

83-2 See response to common issue 2. 

83-3 Neither the O&C Forest Resources Policy (Appendix A) nor the 

district's original planning criteria (Appendix C) suggest that a 
choice among alternatives will be based on comparative costs. Table 
B-l in the FEIS has been expanded to show the forest management costs 
of Alternatives 4 and 9. 

83-4 See response to comment 69-1. 

83-5 See response to comment 11-8. 

83-6 There is a five-year research and development program designed to 
coordinate the research on interrelationships between wildlife and 
old growth forest habitat. Participants include the Bm, USFS Pacific 
Northwest Forest and Range Experiment Station, USFS Regions 5 and 6. 



Robert Burford, National Director, BLM 
William Leavell, State Director, BLM 



BLM's involvement is fully described in a document titled "BLM Role 
in Old Growth Forest/Wildlife Habitat Research, Western Oregon" 
(available at the Oregon State Office). 



141 



BLM will provide financial and technical support to the project as 
well as conduct some intensive studies and research. Objectives of 
the old growth forest/wildlife habitat research program are as 
follows- 

1. Identify animal and plant species dependent on, or which find 
optimum habitat in, old growth forests. 

2. Describe, classify, and inventory old growth forest 
ecosystems. 

3. Determine biological requirements and ecological relationships 
of species found in old growth. 

4. Evaluate old growth management alternatives and their economic 

impacts. 

Research questions related to the northern spotted owl will be 
focused on objectives 1 and 3, as noted above. 

Details on specific research projects are described in the Action 
Plan prepared by the Program leader, USFS Pacific Northwest Forest 
and Range Experiment Station, Olympia, WA. 



83-7 See response to common issue 1. 

83-8 See response to comment 11-3. 

83-9 The nationwide rivers inventory (Jan. 1982) includes two rivers 

involving BLM lands in the Roseburg District: the North Umpqua River 
from the Umpqua National Forest boundary to Rock Creek and the Umpqua 
River from the confluence of the North and South Umpquas downstream 
to the Roseburg-Coos Bay District boundary. No priority rating is 
assigned in the inventory. Interim protection will be given to 
inventoried rivers pending resolution of the Wild and Scenic Rivers 
Act eligibility issue. BLM efforts to determine Wild and Scenic 
Rivers Act eligibility are expected to be delayed until the next 
planning cycle. 

83-10 Chapter 1, Table 1-7 has been revised in the FEIS. Also, see response 
to comments 4-1 and 4-3. 

83-11 The Oregon Legislative Assembly, 1981 Regular Session, House Memorial 
1, is included as an attachment to Letter 71. Consistency with House 
Memorial 1 is believed to be the same as consistency with Forestry 
Program for Oregon goals 1 and 2, shown in the EIS, Chapter 1, Table 
1-7. 



83-12 Non-timber outputs from the withdrawn lands are approximated by the 
analysis of Alternative 1. 




85 



Department of Fish and Wildlife 

506 SW MILL STREET. PO BOX 3503, PORTLAND, OREGON 97208 



August 20, 1982 



OREGON DEPARTMENT OF FISH AND WILDLIFE 

Comments on 

Bureau of Land Management 

Roseburg Timber Management Environmental Impact Statement 

August 20, 1982 

PNRS 820628-068-4 



Mr. James E. Hart 

Roseburg District Manager 

Bureau of Land Management 

777 N.W. Garden Valley Boulevard 

Roseburg, Oregon 97470 

Dear Mr. Hart: 

Attached are the Department of Fish and Wildlife comments 
on the Roseburg Timber Management Draft Environmental Impact 
Statement. 

The Roseburg BLM has the best potential of any other BLM 
district in Oregon to provide viable populations of all 
wildlife species found on the district. It is unfortunate 
that the proposed action does not make that provision. Of 
greatest concern is the loss of cavity nesting habitat, 
and less protection of northern spotted owls than the 
minimum number recommended by both the Oregon Spotted 
Owl Management Plan and the Roseburg BLM Advisory Board. 

We are also concerned with soil erosion, debris avalanches 
and stream sedimentation that will result in degraded fish 
habitat when natural production of anadromous fish has 
been in increasing jeopardy. 

I would like to support your proposed plan but cannot endorse 
a land use plan that does not at least maintain viable 
populations of all existing species of wildlife. I 
urge your proposed plan be altered to provide for those needs. 



85-1 



85-2 



incerel 



-k 



f r 



(^ j/hn R. Donaldson, PhD 
"Director 



85-3 



After staff review of the draft EIS, we would like to see the following items 
clarified or addressed in the final EIS. The items are of significant concern 
to the Department. 

General Comments 

Mining - 

We are aware that the plan is a timber management plan, but we are also concerned 
with the impacts of mining on Roseburg District lands. Mining has had severe 
adverse impacts on the fish resources of the area and adequate control must be 
exerted if full use of both fish and mineral resources is to be realized. We 
trust that the FEIS will address mineral resources, and the measures that the 
BLM will take to protect fish resources during mineral exploration and development. 

Mitigation of Impacts - 

I We mentioned in our input dated February 5, 1981 and June 12, 1981 that the impacts 
of other resource development can be mitigated. Expected mitigative techniques 
need to be clearly outlined in the Alternatives. Snags, dead and downed 
material are wildlife habitats that can be provided during timber harvest 
operations. Herbicide applications can have adverse impact on forage production 
for big game but the impacts can be mitigated by considering the supply of 
forage nearby and applying herbicide on a portion of the treatment area if 
forage is in short supply. Road closures can prevent harrassment of big game 
where necessary. These are examples of mitigative techniques that can be 
provided regardless of the alternative selected. 

Maintenance of Viable Populations of Wildlife - 

According to the DEIS only Alternative 8, if implemented, will maintain viable 
populations of indigenous species. The Department cannot endorse any proposed 
land use plan that does not at least maintain all existing populations of wildlife. 

Specific Comments 

Page 4 - Summary of Environmental Consequences 

Please clarify the paragraph describing the environmental consequences on water 
resources. That paragraph discusses the impacts of all alternatives except the 
perferred alternative. Sediment yields would increase under Alternatives 1,3 
and decrease under Alternatives 5 through 8. What is the expected impact of 
the preferred alternative on sediment yield? The information supplied in the 
EIS suggests sediment yield would increase as a result of implementing the 
proposed action. 



|42 PNRS 820628-068-4 
August 20, 1982 
Page 2. 



PNRS 820628-068-4 
August 20, 1982 
Page 3. 



Alternative 4 states: "this Alternative is identical to Alternative 3 except..., 
and Alternative 3 will increase sediment yield. 

Analysis of impacts on water resources does not include fish life or animals. 
Under recreation there is brief reference that fishing would be adversely im- 
pacted under Alternative 1, 2, 3 and 5. Please quantify expected impacts on 
cold water fish. 

o5*4 Page 5. The section on animals needs to be expanded to discuss the impacts on 
fish. Increases in water temperature in Alternatives 1 and 5 would negatively 
impact fish. The impacts, however, of implementing Alternative 4 are not dis- 
cussed and need to be clearly listed. The information presented in the EIS 
leads us to believe the proposed action would adversely impact fish. Sediment 
yield and stream temperature are already limiting fish populations of Oouglas 
County. Page 4 of the EIS says "based on the sample five year sale plan, tim- 
ber harvest activities planned in four municipal watersheds would increase 
water yield and sedimentation." 

Page 13 and page 14 discuss land classifications being managed by Roseburg 6LH. 
and C lands and Coos Bay Wagon Road Grant lands are to be administered by 
the and C Act of 1937 only where the Act conflicts with FLPMA. Public domain 
lands, of which 18,000 acres exist unde' Roseburg BLM jurisdiction appear to be 

I managed in accordance with the and C Act. What is the legal justification 
for managing public domain lands under the and C Act rather than under pro- 
visions of the Federal Land Policy and Management Act of 1976? 

Page 24 - Summary of Impacts 

The environmental component category soils indicate that 3,072 acres per decade 

I of Roseburg BLM will suffer loss of productivity. Please explain how produc- 
tivity on 5 square miles per decade can be lost and still meet the intent of 
Clean Water Act, Sikes Act, FLPMA, NEPA and Executive Order 11990. 

I The summary of impacts lists expected changes in Roosevelt Elk and northern 
spotted owl populations. The chart should also indicate the changes in snag 
dependent wildlife and fish populations. 

Page 44 - Terrestrial Animals 

We agree with the statement "of special concern are snags. Snags provide opti- 
mum habitat for 33 species and are used, to some extent, by 47 other species of 
birds and mammals." "Recent snag surveys by district personnel revealed an av- 
erage of 0.1 snags per acre in coniferous forests less than 15 years of age 
under BLM administration." The discussion continues indicating the snags are 
essential to cavity nesting birds and those birds feed on insects and play an 
important part in the control of forest insect pests. We believe that the 
maintenance of snags is important and that the Bureau should take greater meas- 
ures to provide two snags per acre on clearcut lands instead of 0.1 that are 
presently existing. 



Page 45 - Riparian Habitat 

Riparian habitat on third order and largo 

forest land base, some of which has been altered by pa'.' 

I practices and is in less than optimum condition. What would 
allowable harvest by protecting all riparian habitat on third ordi 
instead of harvesting half the timber volume? 

Page 66, Table 3-2 indicates the soil productivity win 

miles of land on the Roseburg District due to road action 

and landsllding from fragile soils. More damage to soil will result from 

graveling and nutrient depletion but no data is available to indicr 

of damage. On page 67 the discussion of water qua 

i ;e by 23 times the natural rote on BLM 
to NEPA, an environmental impact statement sho.r 

(reduce long-term adverse environmental impacts. What impacts on fish and wild- 
life resources will result from the loss of productivity of 12 square miles of 
BLM land and the increased suspended sediment yield from sluiceouts and head- 
wall fdi lures? 

Page 73 - Environmental Consequences, Timber Harvest 

The second paragraph of this section briefly Aev oposed modified area 

control management and the location of habitat diversity features in a corridor 
.-[concept. The final EIS needs to show the location and the wi nidified 

85'10l.irpa control corridors. It is our understanding from a meeting we had w 
Bureau in 1981 that in many places, particularly the southern portion ol 
Roseburg District, that the corridors appeared to avoid productive BLM Lands 
and, instead, were routed through private lands over which the BLM has no con- 
OC ^^l tro1 - The Final Environmental Impact Statement should predict the effectiveness 
O»3'11lof these corridors and how they tie in to corridors proposed by other BLM districts. 

Page 73 - Timber Harvest, Third Paragraph, First Sentence: 

Late in the third paragraph, the statement made: "the loss in useable old- 

I growth habitat is greater than it appears in appendix F,..." In the final 
impact statement, please indicate how great the loss in useable old-irowth 
habitat actually is. 

Page 74 - Timber Harvest, First Paragraph, First Sentence: 

We agree with the statement that only Alternatives 6, 7 and 8 will assure 
the maintenance of viable populations on animals throughout the Roseburg BLM. 

Page 74 - Timber Harvest, Fourth Paragraph, First Sentence: 

This paragraph discusses the Tyee area and its importance to elk that presently 
exist in that area. Please explain in the final impact statement why there are 
no long-term provisions for retaining mature or old-growth forests beyond the 
fourth decade in the Tyee area. 



PNRS 820629-068-4 
August 20, 1982 
Page 4. 



PNRS 820628-068-4 
August 20, 1982 
Page 5. 



85 



4 



Pages 74-75 - Timber Harvest, First Paragraph 

These two pages discuss the quantity of snags left after timber harvest and 
the importance of snags in maintaining viable populations of wildlife depen- 
dent on snags. The quantity of snags left, at today's rate of cut, (0.1 
snag per acre) is well below that needed for viable populations of dependent 
species. Two snags per acre has been shown to be the minimum number needed 
to provide viable populations of those species. 

Table 3-10 on page 75 indicates the preferred Alternative will provide snags 
at a level that will depress the population of snag dependent species to 20- 
30 % of potential. That level will not maintain viable populations of those 
species. Table 3-10 also indicates that Alternative 6 and 7 might maintain 
viable populations, and only Alternative 3 would surely allow viable popula- 
tions to exist. It is possible and desirable to leave snags during harvest 
operations. In the final impact statement, please explain why mitigative 
techniques will not be implemented that will assure the continued existence 
of snag dependent species. 

Page 76 - Paragraph Two, First Sentence: 

We agree that without mitigating prescriptions, impacts on elk populations 
would be more extensive than those shown in Table 3-11, page 79. Table 3-11 
is based upon forage-cover ratios generally accepted by wildlife biologists 
in the Roseburg area. 

Page 77 - Second Paragraph, First Sentence: 

Discussed are the impacts of pre-commercial thinning on big game. Discussion 
indicates that pre-commercial thinning can impede the movement of big game if 
slash is unremoved. According to the DEIS, slash will not be removed, thereby, 
adversely impacting big game. Please explain in the final EIS why travel 
lanes will not be provided for big game or why slash will not be removed from 
thinned areas. 

Page 77 - Transportation System, First Paragraph, First Sentence: 

The five year timber sale plan shows about three miles of road would be built 
on fragile or unstable soils adjacent to streams with fishery values. If sedi- 
mentation increases, the impacts would be adverse and be significant. Earlier 
in the DEIS, a statement is made that road construction does lead to increased 
sedimentation. 



Page 78 - Fifth Paragraph, First Sentence: 

QC IPlease explain why the five year timber sale plan has 26 harvest units on 
O^-lglunstable soils adjacent to streams with cold water fish values. It is the 
Department's belief that timber harvest should occur where fish habitat will 
not be damaged. It is evident from this paragraph in the EIS that timber 
sales are planned in areas that will prove harmful to fish resources. 

Page 78 - Threatened and Endangered Animals 

The fifth paragraph of this section indicates the five year timber sale plan 
will impact habitat of nearly one half the known pairs of spotted owls. We 
regard this loss as serious and of Immediate concern. 

Oregon Revised Statute 496.012 says in part: "It is the policy of the State 
of Oregon that wildlife shall be managed to provide the optimum recreational 
and aesthetic benefits... in furtherance of this policy, the goals of wildlife 
mangement are: (1) To maintain all species of wildlife at optimum levels and 
prevent the serious depletion of any indigenous species." 

Whether or not old-growth and spotted owl habitat has been seriously depleted 
at this time may be debated but it is apparent that land management continued 
on a status quo basis will seriously deplete that habitat type in the future. 
The application of State law to federal land is best addressed by the legal 
profession but there may be a responsibility of the BLM to consider that 
statute in formulating land use plans. 



85 



'-14 



Final impact statement, please quantify the impacts on fish that will 
result from building three miles of road on fragile and unstable soils; also, 
please justify those increases and adverse impacts in light of the statement 
on page 78 that says: "increases in bottom sediments, according to Gibbons 
and Saylo (1973), cause the most damage of all factors affecting fish life." 



143 



Response to comments in Letter 85. 

85-1 This is beyond the scope of the EIS which is restricted to timber 
management See response to comment 2-1 

85-2 See response to comment 5-3. 

85-3 The text has been revised in the FEIS. 

85-4 Refer to DEIS, Chapter 3, page 79, for impacts on fish. Also, see 

response to comment 74-3. 

85-5 See response to comment 7-1. 

85-6 Refer to DEIS, Chapter 3, Table 3-2, for details. Most of the loss is 
due to compaction. 

85-7 The text has been expanded in the FEIS, Chapter 1- Table 1-5. 

85-8 Refer to Appendix C, Table C-4, for comparison of riparian areas. 
None of the alternatives provides for harvesting half the timber 
volume. 



Alternatives 2, 3, 4, and 7 employ modified area control (DEIS, 
page 124) for the riparian zones along third order and greater 
streams. The sample five-year timber sale plan, as described in the 
DEIS, Impacts on Animals section, page 75, indicates a yearly average 
of 12 acres clearcut and 96 acres partial cut in the above areas. If 
these areas were removed from the allowable cut calculation, as in 
Alternatives 6, 8, and 9, an estimated decrease of 500 MCF or 3 MM 
bd. ft. would occur. 

85-9 The DEIS indicates impacts are insignificant. Also, see response to 
comment 74-3. 

85-10 Maps are available for inspection in the Roseburg District Office. 

85-11 Corridor alternatives adopted or proposed by other BLM districts 
which adjoin Roseburg (i.e., Coos Bay and Eugene) have been 
considered and are coordinated with Roseburg District alternatives. 
Effectiveness will be monitored over time. 

85-12 The text has been revised in the FEIS, Chapter 3, Terrestrial 
Vertebrates, Timber Harvest section. 

85-13 Conflicts with operator safety requirements preclude snags frcm being 
left on many harvest operations in the intensive forest management 
base. Although options to leavirg snags exist (e.g., topping trees), 
those options where the cut level would be reduced to the point of 
changing an alternative would not be planned. Also, see response to 
comment 5-3. 



85-14 Refer to DEIS, Chapter 3, page 79 for impacts on fish. Also, see 
response to comment 74-3 

85-15 Adverse impacts can be mitigated through project design features, as 
described in DEIS, Chapter 1. 



SEATTLE, WASHINGTON 98101 



U.S. ENVIRONMENTAL PROTECTION AGENCY 
<(eo st^ R E G t O N X 

v, ^^ r 1200 SIXTH AVENUE 

"two? m/S 443 

32 



86 



86-1 



James E. Hart, Oi strict Manager 
Roseburg District Office 
Bureau of Land Management 
777 NW Garden Valley Blvd 
Roseburg, OR 97470 

RE: Roseburg Timber Management Program DEIS 

Dear Mr. Hart: 

The Environmental Protection Agency (EPA) has completed reviewing the DEIS 
for the Roseburg Timber Management Program (TMP). The DEIS adequately 
presents the program and the various alternatives available for its 
implementation. 

We would like to offer the following comments on Chapter 3 (ENVIRONMENTAL 
CONSEQUENCES) which may serve to improve the discussion in the Final EIS. 

Checkerboard Lands Pattern 

Lands under 8LM management, in the Roseburg District as well as other 
western Oregon districts, are largely in a checkerboard pattern. The map 
accompanying the DEIS shows these lands to be widely dispersed in a 
"circle" surrounding Roseburg. This land distribution pattern creates 
special problems for managing the environmental consequences of the 
TMP when both the causes and the mitigating measures constantly cross and 
recross the boundaries of BLM lands. Any special limitations and controls 
to address this problem should be described in the Final EIS. It would 
also be helpful if the Final EIS noted any cooperative arrangements or 
joint actions being undertaken with adjacent land owners for managing the 
boundary-crossing environmental consequences of the management program. 



144 



Air quality 

We cannot locate the reference to a 30-35 mile distance for slash burn 
plume dispersion, beyond which "(p)ollutants ... dre usually mixed by wind 
and dissipated..." (citing EPA, 1978). The report cited indicates that a 
100 mile distance is a more appropriate measure to evaluate plume disper- 
sion and potential effects on Class I and non-attainment areas. There are 
four Class I areas (Diamond Peaks, Three Sisters and Kalmiopsis Wilderness 
* _ Areas, and Crater Lake National Park) and two non-attainment areas (Medford 
OD"t and Eugene) within 100 miles of the Roseburg District lands. The final E1S 
should discuss and evaluate the potential effects of slash burning on air 
quality in these Class 1 and non-attainment areas and indicate appropriate 
smoke control measures to avoid smoke intrusions in these areas. 

We recommend that you consult with the Oregon DEQ for current data about 
particulate emissions from slash burns and for assistance in quantifying 
the effects of slash burns. 

The OEIS does not discuss potential alternatives to slash burning which 
may provide viable air quality control measures. Various post-harvest 
management techniques should be included in the discussion of air quality 
management, or this section should reference other parts of the EIS where 
they may be discussed. 

Human Health Effects & Potable Water Supplies 

I Page 86 of the DEIS indicates that the "...number of people that could be 
86" 41 directly affected by herbicide application in the planning area is small," 
I but presents no demographic or land user data to support this point. We 

recommend that quantitative information be provided to support this conclu- 
I sion. This discussion should include an assessment of possible herbicide 
OD - 5| accumulation in drinking water supplies [the DEIS (p. 69) notes four 

I municipal watersheds on BLM lands]. The FEIS should indicate whether the 
oe_C| 'MP will cause or contribute to any violations of the Interim Primary 
OD~0| Drinking Water Regulations in the affected water supplies. 

I The final EIS should discuss and evaluate alternative vegetation manage- 
ment techniques, such as on-ground spraying or hand cutting, which may 
minimize unwanted environmental consequences of aerial spraying. 

Finally, we recommend that you coordinate this part of the EIS with the 
work now being done through the Salem District Office to prepare a DEIS 
for BLM's Westside (Oregon) vegetation management program. 



Water quality 

Page 69 of the DEIS indicates that buffer strips are expected to minimize 
herbicide drift or accidental spraying of water courses. However, Table 
3-5 shows varying amounts of timber harvesting will take place In bill 
strips. The two alternatives which Include no harvesting In buffer strips 
show that sedimentation can be reduced by approximately 150,000 tons over 

I the first decade of the program. This apparent contradiction should be 
clarified, showing any relations between extent of spraying in areas 
around streams, and the amount of buffer strip harvesting. 

Tables 2-5 (p. 39) and 2-7 (p. 41) seem to Indicate that most major 
streams within the Roseburg District suffer from severe sedimentation 
problems. Timber harvesting within the District will exacerbate this 
problem. The DEIS recognizes this situation but is unclear about measures 
which may be implemented to minimize sedimentation and to meet and 
maintain water quality standards. One control which appears viable is to 
preserve, or widen as appropriate, streamside buffer strips. Table 3-5 
(p. 68) indicates that extensive cuts are to be made in existing buffer 

I strips. We recommend that these buffer strips not be cut, and that the 
Final EIS identify and evaluate potential mitigation measures which could 
be used to reduce the sedimentation problems identified in the Draft EIS. 
. — I It should also indicate whether the streams currently meet the applicable 
86 10l wat er quality standards and how each of the alternative timber management 
^programs would affect water quality standards compliance. 

EPA has rated this EIS 10-2 [LO: Lack of Objection; 2: Insufficient Infor- 
mation]. We appreciate the opportunity to review the report. Should you 
desire to discuss EPA's suggestions, you may contact Mr. Dick Thiel, our 
Environmental Evaluation Branch Chief, at (FTS) 399-1728 or (206) 442-1728. 



y£ 



Sincerely, 



V- John R. Spencer, 

Regional Adminstrator 



Response to comments in Letter 86. 

86-1 The DEIS, Chapter 1, describes Memoranda of Understanding, 

Cooperative Agreements, Permits and other instruments appropriate for 
managing the intermingled ownership pattern of the O&C lands. Also, 
see response to comments 4-4, 5-3, and 58-3. 

86-2 The text has been revised in the FEIS, Chapter 3, Impacts on Air 
Quality section. 

86-3 Alternatives to slash burning and other related issues will be 

addressed in an EIS on Vegetation Management for western Oregon. The 
Draft EIS is being prepared and is expected to be published later in 
1983. 



86-6 The timber management plan is not expected to result in violations of 
the Interim Primary Drinking Water Regulations. BLM cooperates with 
the Oregon Department of Environmental Quality as well as the 
affected municipalities through Memoranda of Understanding, as 
described in the DEIS, Chapter 1, pages 27-29. 

BLM timber harvesting, road construction, chemical applications, 
slash disposal and reforestation requirements meet or exceed the 
Oregon Forest Practices Act standards, as indicated on page 27 of the 
DEIS. 

86-7 Alternative 7 in the DEIS evaluates this point. The new EIS on 

Vegetation Management will specifically address a no aerial spray 
alternative. 



As part of BLM's planning process a determination of the number of 
residences within 1/2 mile of BLM land was made. Approximately 9,600 
rural residences are within the boundaries of the Roseburg District. 
Of these 3,413 or 36 percent are within 1/2 mile of BLM land. Only a 
few percent are affected in any given year. These are detailed in 
site specific environmental assessments prepared for vegetation 
management and other projects. 

This issue was addressed in the FEIS, Vegetation Management with 
Herbicides: Western Oregon 1978 through 1987. Refer to DEIS, Chapter 
1, page 20, which incorporates the above FEIS by reference. In 
addition, the new EIS on Vegetation Management will address the 
issue. 



86-8 Streamside buffers for water quality protection during timber 

harvesting operations are different from those streamside buffers 
associated with herbicide spraying. The EIS, in Appendix C, Table 
C-4, identifies protective measures proposed during timber harvest 
operations along streams (riparian zones). Protective stream buffers 
applied during herbicide spraying operations are identified in the 
DEIS, Chapter 1, page 22, Plantation Maintenance and Release section. 

86-9 Alternatives 6, 8, and 9 do not include any harvest within buffer 

strips. Mitigation is described in DEIS, Chapter 1. See response to 
comment 5-3. 

86-10 See response to comment 15-6. 



90 



145 



/Kvj\\ United States 
UUkI// Department ot 
\»A/ Agriculture 



Pacific 
Northwest 
Region 



319 S.W. Pine 
P. 0. Box 3623 
Portland, OR 32208. 



1950 

August 20, 1982 



Mr. James E. Hart, District Manager 
Rojeburg District Office 
777 N.W. Garden Valley Blvd. 
Roseburg, OR 97470 



Dear Mr. Hart: 

We appreciate this opportunity to comment on the Roseburg Timber 
Management Draft Environmental Impact Statement. The Umpqua National 
Forest and Roseburg District are linked by several mutual management 
concerns and the opportunity to address them. There is also a shared 
opportunity to be responsive to the public in the management of resources 
which seek habitat rather than heed administrative boundaries. 
Significant among these are elk and northern spotted owl, the latter 
being inextricably linked to old-growth forests. 

We are concerned that, though there has been much coordination between 
Forest and Bureau of Land Management Roseburg District personnel, the 
proposed action does not reflect this coordination or recognize that 
certain decisions about District management affect resource management on 
the Umpqua National Forest. 

The number of northern spotted owl pairs recommended for testing in the 
Umpqua National Forest planning process is based on the Oregon 
1 Interagency Spotted Owl Management Plan. Roseburg's proposal to not 
90 il mana 9 e i n accordance with recommendations of that plan may have 
I impl i cations on the number recommended for the Umpqua. 



90-2| 



Similarly, the District's planned reduction in elk habitat could place a 
burden on National Forest habitat resources. We would like to have these 
implications considered in your decision. 

We also have an interest in methods of analysis you have used which may 
be applicable to National Forests and add consistency to our planning. 
Of particular interest are estimation techniques used in assessing water 
resource effects and your rationale linking mitigation provisions of the 
several alternatives and Federal law. 



Mr. James E. Hart 



Another area of concern is the timber growth prediction attributed to 
fertilization as it may be interpreted to apply on National Forest 
lands. Although we agree that this practice can increase yields we have 
little information on response from the Umpqua National Forest. Umpqua 
yield tables, therefore, are necessarily more conservative. 

We look forward to continued close cooperation with the Roseburg District 
in formulating the Umpqua Forest plan. Together, the two plans will 
provide the major thrust for Federal land management in the next decade 
in Douglas County. 



Sincerely, 




^*£. 



EFF M. SIRMON 
Regional Forester 



FS-62CO-1 1 (8-80) 



91 



Response to comments in Letter 90. 

90-1 The text has been revised in the FEIS, Chapter 3, Impacts on Animals 
section, indicating that if BUI does not manage for the number of 
pairs allocated to it in the Spotted Owl Management Plan, the unmet 
portion would revert to the Oregon Endangered Species Task Force to 
consider possible reapportionment. 




INDUSTRIAL FORESTRY ASSOCIATION 



2680 NO PACIFIC HIGHWAY 
MEDFORD. OREGON 97501 




-.11 u t 



90-2 The text has been revised in the FEIS, Chapter 3, Impacts on Animals 
section. 



91-1 



91 2 



James E. Hart, District Man 
Bureau of Land Management 
777 NW Garden Valley Roulevard 
Roseburg, Oregon 97470 

Dear Jim, 

I am Southwest Oregon Di 
located in Med ford at 2680 North Paci fie Highway . 
about 90 timber industry comj 
which purchase timber on the Roseburg mil District. 

I would like to thank the BLM for t 1 ' 
the adequacy of the Roseburg Disl 
attempt to predict environmental impacts resu 
actions. The interdisciplinary 
efforts. 

in extensive effort, however, i 
as a guide to decision makers. Sever.il are 
leading and may confuse decision make] 
hensive timber management plan which will I 
of the Roseburg study area. 

To begin with the analysis of the cui : 
adequate. Comparing it with the other seven alternatives is liki 
apples and oranges. Alternative b use: . the old stand i 
and yield data, while the other 
native 3 were chosen as the basic, of the future t 
assume you would use the new invi 
now proven to be incorrect. Alt, 



now proven to De incorrect, ttitern 
using the new inventoi 
compare all eight alternatives. II |ust 
Alternative (#4) is actually a proposed 
Roseburg BLM District. 

Another unclear and misle 
Page 23 indicates the greatest habitat modil 
5. On page 24, table I 
modification. Table 1-5 

to a greater extent than Alternative 1, even 
acres than Alternative 1 and prt ut . 



146 



James f . 
Page 2 



Hnrt , Di 



James I 
Page 3 



913 



: . ■ ■ : 

il will 

■ 

■ ■■ 
■ 

i sm or 

■ 
■ 

Bed on t .i 1 1 

Ibro;ni No ment ion 

15 made i on for 

cavit locument, de- 

cadent, sna considered estheti ng. An 

attempt should be made in tin , of impacts 

relat ii ■ 

On pages 60, 61 , toil 62 an atti I o desci ibe the economic 

of t i ient on Local econi i n, In this in IS, the data i 

sented in 1976-1978 dollars, for I 1 n't understand how 

predirt Spotted Owl population levels i" fin- tOth decade, yet we can'l 
economic discussion presented in current dollar values. It seems to me m 
current economic data would be more meaningful to a decision maker. In the n !'■ 
it would he helpful to know if the figure-, in Table 2-26 (Economic Affects of 
I isheries, Hunting, and Recreation) and the summary on page 62 are also in 1976- 
1978 dollars. 



91 5 



In addition to the above general thoughts, which I presented in oral testi- 
mony at the August 18th public hearing, I would like to add the following more 
specific concerns and recommendations for your consideration in evaluating the 
adeguacy of the DEIS. 

1. Alternal , Linkage to the new policy on BLM 0&[ Lands, 
Onl) alternatives 1 and to determining harvest based on 

1 i mi ted landbase withdrawals for other resources. 

I Recommendat i ons : All alternatives should be redeveloped based on the new BLM 
planning criteria. If necessary, a new proposed action should be developed 
either in the final EIS or a new Drat! 

2. Departurealternatives, '[though actually calculated, were given essent- 
ially footnote coverage in the DEIS. NEPA requires the agency to fully 

1 1 ill alternatives even if they violate current law or policy. The 
description in the EIS that the departure analysis is not "useful enough" 
te. It is obvious that significant increases in current and 
md growth is possible with a departure as compared to 
the pro; 



^- — I Recommendations: fully analyze several v 
y | — * |socioeconomital and environmental effects 



able departure 
in the FEIS. 



.1 ternat lves for their 



91-8 



I 
under the A.C.E. corn i , 
at ion valu 

■ 

uea only gi vi 

■ 
value of the land. I 
is worth when sold in the market p 

mkings. One question wi 

higher S.E.V. regimes, why was the Li 
the preferred alternal 

IThe price assumptions are overly optimistic interims of futun 
it , the current price is about one-h i 
for timber values also appear to be overly 

„«/>|^' " 1( cos *- factors 
9l~*10| ' l than has been recent ex;. 

|on Industry lands, or (2 tiated. 

Recommendation: Completely redo the economic analysis to reflect the true cur- 
rent costs and revenues generated by management and evaluate returns exclusive 
of the ACE effect. 

5. We are extremely concerned at the BLMS proposal to reduce the landbase 
by some 44,000 acres, increase the management intensity through higher bud- 
get dollars, and thereby mere i. While we 
approve strongly of intei 'ment and the leadei 
shows in this area, we are concerned about the use of intensive management 
to trade away acres for unsubstantiated other resource use3. The increase 
in budgets required to be successful m this program will likely not be 
there in the future. Thi entire timber pro- 
gram predicated on some very shaky i r>s. One solution to 
the dilema is to alter the forest management intensity to reflect better 
budget expectations and make up the loss in production from additional al- 
locations of timberland from nontimbei 

I Recommendation: Reformulate the alternatives into proposed programs which are 
more in line with realistic budget assumptions, and clearly display what the 
increases in budgets expected are for each increment of additional allowable 



Sincerely yours, 



D i r>K-.^rl U C~ 1 -l~ .• ' 



Richard H. Felgenhou 
District forester 



Response to comments in Letter 91 

91-1 Council on Environmental Quality {CBQ) Regulations (40 CFR 

1502.14(d)) require a No Action Alternative to be included in 
environmental impact analysis. 



91-6 The FEIS includes a new Preferred Alternative (Alternative 9). 
Also, see response to comment 12-1. 

91-7 Refer to Appendix B, Results of Scoping. Also, see response to 
comment 78-4 . 



91-2 The text has been revised in the FEIS, Chapter 1, Comparison of 

Impacts. Differences relating to the amount of old growth existing at 
the end of the first decade under Alternatives 1 and 5 are explained 
in the DEIS, Chapter 3. Table 3-8. 

91-3 See response to common issue 1. 

91-4 Although positive effects on cavity dweller habitat would result from 
herbicide treatment to broadleaf species, such treatment would not 
provide significant wildlife benefits due to the scattered 
distribution of broadleaf species in the Roseburg District. 



91-8 See response to comment 68-19. 

91-9 Average sales value per M bd. ft. for timber sold by the Roseburg 

District was $260 in FY 1981 and S94 in FY 1982. These baselines have 
been added to Appendix B, Table B-2. 

91-10 See response to common issue 5. 

91-11 See response to common issue 2. 



91-5 Table 2-26 has been revised in the FEIS to include a footnote which 
indicates that the estimates of personal earnings reported are 
adjusted to the average wage and price level which prevailed in 
Oregon between 1976 and 1978. In order to sum the results of Tables 
2-25 and 2-26 (page 62, DEIS) the estimates of personal earning must 
be in dollars of the same period. The most recent year in which data 
were available for all resource categories evaluated in the plan was 
1978. 



93 



147 



984 Lincoln 
Eugene, Ore. 97401 



Roseburg District Manager 
Roseburg District Office 
777 N.W. Garden Valley Blvd. 
Roseburg, Ore. 97470 



Following are my Garments on the Roseburg Timber Management Environmental 
Impact Statement. 

I am continually appalled tl^at the BLM could write an EIS so curiously 
descriptive and graphic concerning the impacts to wildlife, and yet propose 
to make those very decisions having the worst effect. The EIS admits that 
continuing timber management at Uae proposed level will ruin forest diversity; 
that elk survival cover will be greatly reduced, leading to a 20% decline in 
the population; that mortality salvage will eliminate snags; that the preferred 
alternative will cause a 34% decline in old growth after one decade, and a 
ridiculous 71% decline after a century; that the Tyee area contains none of the 
old growth management, et cetera. 

It defies comprehension for the Roseburg District to say that the spotted 
owl is a potential candidate for threatened and endangered status, yet propose 
an alternative that does not aid its long term cliances for survival. Likewise 
with clioosing an alternative that follows tlie Forestry Plan for Oregon, but 
does not follow the Oregon Department of Fish and Wildlife recommendations. 

Nothing in the O&C Act requires this sort of donu-nant use. It is especially 
ridiculous to raise the allowable cut when, due to the deep recession, billions 
of BLM board feet are sold but not yet cut. Simply selling more will only further 



93-1 



depress an already disastrous market. 

When will foresters realize that wildlife and tunber management are not 
separate disciplines; tliat both rest, and 

tliat it is not good enough to consign wildlife to the 
inant timber program. The excuse has always been the O&C 
does not mention wildlife, BLM need not worry about 
attitude. Forest management is not synonymous with timber management. 

Tlie O&C Act does mention watershed management. Amajor c 
management is riparian zone preservation, which fares rather . ■ 
preferred alternative. It is the first and second order streams, the beginnings 
of the major rivers, whose riparian areas are not being protected at all. 

The EIS, like many of its ilk, goes into gruesome detail on wildol 
which is laudatory. But it never explains the forestry program in hurt;.' 
It is not necessary to include a detailed and complicated analysis of 
allowable cut's derivation. But it is important to explain truthfully how the 
allowable cut is derived; the use of the allowable cut effect; and the rationale 
for the allowable cut. Itone of these things are done. There is no explana- 
tion for why tlie cut goes up so highly in this EIS. 

In light of the fact that nutters are not settled on Coos Bay, and that a 
corridor system may be the only viable way to settle the remaining old growth 
into a workable system, I shoula think it liastyi to espouse an alterr^ 
like this one. 

Sincerely, 

Cameron La Follette 



Response to comments in Letter 93. 



93-1 The text has been revised in the FEIS, Appendix C, by the addition of 
Figure C-2. Also, see response to comment 16-40. 




94 



UNITED STATES DEPARTMENT Of COMfVlf RCf 
Nation.il Oceanic and Atmosphc 



September 17, 1982 



District Manager 
Bureau of Land Management 
Department of the Interior 
777 NW Garden View 
Roseburg Boulevard 
Roseburg, Oregon 97470 

Dear Sir: 

This is in reference to your draf f envii 
entitled "Roseburg Timber Managenent." The ei 
National Oceanic and Atmospheric Administration are 
consideration. 

Thank you for giving us an op; 
which we hope will he of assistance to you. We would d| 
four copies of the final environmental impacl 

Sincerely, 



Joyce M. Wood 
Director 
Office ol 



Enclosure: Memo from: Dale R. Evans 

National Marine Fisheries 



^ 



148 




UNITED STATES DEPARTMENT OF COMMERCE 
National Oceanic and Atmospheric Administration 









, 



if- 



Sub;. 
cor.: 

The 
doc 

COUl-i :rces. 

ut could ent. in 

For caused by lai 

■ order 

total of ton :.r of the soi seburg 

SYUs are ( I m d Problem soils (Table 2-4) , i 

In other cases, a small 

is dam could block access to all ■ liomous 

tal i roi i to I 
;ent document. 

Specific O : 

-.. .1 Animals. There is no mention of possil of the 

y^T _ l posed action would increase water yield 

' rsheds, there must be some impact on fish. 



Q4-OI Ic 1-5. Summary of Imp 

^" ^1 ts en fish habitat. 



The table does not include an 



Pa 1 e 26 - Federal Agenel.- 



94-3 



94-4 



94-5 



response 

md anadtomou 

Resour he Coastal Zoi 

Environ in d makes recoi 

Il DIBOUS f ish*-r . n ana > 

Wildlife Coordination Act. 



Soils. Table 2-4, Fragile and Problem Soil- . 



Pages 34-36 

to Figure 2-2, • . Q f the table and I 

correspond, even considering the < 

compare and 



age 46, Table 2-11 



_ Salmonid Fish Habitat and Papula*: i 
i 'ual miles of fish habitat. Some habil 



by more than om 
year. 



94-6 



im and downstr 

r quality and quant 
: for fish mig ratioi 
should i :. impact on fish caused by the propos< 

quant i : 

I Page 77. Fish . Whi 
and the section on ; 
the consequent i .rious altern. 

discussed. 



larly concerned for the n 
buffer strips tor streams. We strongly urge inc 
action (or into whichever alternative ii 
provide for protection and enhancement of fish i 



integrity oi I 

the proposed 

which 
irea. 



11 



I Special attention should be given to bank protection on first and second order 
as well as higher order streams to prevent sed 
protection for all Class I streams against sedimentation and in-.- 
temperatures. 

Inasmuch as future declines in timber auppli 61), it 

would seem prudent to protect alternative economic resources as much 
possible. 



^^^ 



Response to comments in Letter 94 

94-1 See response to comment 74-3 

94-2 See response to comment 74-3. 

94-3 Tiie text has been revised in the FEIS, Chapter 1, Interrelationships 
section 

94-4 The text has been revised in the FEIS. Chapter 2. 

94-5 The total miles of salmonid habitat are indicated in the DEIS, 

Chapter 3, page 77. it can also be determined from Chapter 2, Table 
2-11, by adding the miles of 8LM habitat for resident trout. 

94-6 See response to comment 85-4. 

94-7 Refer to DEIS Chapter 3, page 79. Also, see response to comment 
74-3. 



94-8 Refer to DEIS, Appendix C, Table C-4. 



149 



LIST OF AGENCIES, ORGANIZATIONS AND PERSONS TO WHOM 
COPIES OF THE STATEMENT ARE SENT 



Comments on the draft environmental statement were 
requested from the following: 

Federal Agencies 

Advisory Council on Historic Preservation 
Department of Agriculture 

Forest Service 

Soil Conservation Service 
Department of Commerce 

National Marine Fisheries Service 
Department of Defense 

U.S. Army Corps of Engineers 
Department of Energy 

Region X 
Department of the Interior 

Fish and Wildlife Service 

Geological Survey 

National Park Service 

Bureau of Mines 

Bureau of Reclamation 
Small Business Administration 
Environmental Protection Agency 

State and Local Government 

Oregon State Clearinghouse 
Oregon Regional Clearinghouses 

Lane Council of Governments 

Umpqua Regional Council of Governments 

Rogue Valley Council of Governments 
Oregon State Historic Preservation Officer 
Boards of County Commissioners 

Douglas County 

Copies of this environmental impact statement will be 
available for public inspection at the following BLM offices: 



Interest Groups (partial listing) 

American Forest Institute 

Associated Oregon Industries 

Association of O&C Counties 

Cascade Holistic Economic Consultants 

Friends of the Earth 

Industrial Forestry Association 

Izaak Walton League 

Natural Resource Defense Council 

National Wildlife Federation 

Northwest Environmental Defense Center 

North West Timber Association 

Oregon Environmental Council 

Oregon Natural Heritage Program 

Oregon Student Public Interest Research Group 

Oregon Wilderness Coalition 

Sierra Club 

Southern Oregon Citizens Against Toxic Sprays 

Southern Oregon Resource Alliance 

Southern Oregon Timber Industries Association 

The Wilderness Society 

Western Forest Industries Association 

Wildlife Management Institute 



Roseburg District Office 
777 NW Garden Valley Blvd. 
Roseburg, Oregon 97470 
Phone (503) 672-4491 



Washington Office of Public Affairs 
18th and C Streets 
Washington, D.C. 20240 
Phone (202) 343-5717 

Oregon State Public Affairs Office 
825 N.E. Multnomah 
P.O. Box 2965 
Portland, Oregon 97208 
Phone (503) 231-6277 

Reading copies will be placed in the following libraries: Portland State University, Portand; Oregon State University, 
Corvallis; University of Oregon, Eugene; Lane Community College, Eugene; and Umpqua Community College, 
Roseburg; and public libraries in Salem, Canyonville, Drain, Glendale, Myrtle Creek, Riddle, Roseburg, Winston and 
Yoncalla. 



Copies of the final EIS are sent to each person, organization or agency commenting on or receiving copies of the draft 
document. 



150 



LIST OF PREPARERS 



While individuals have primary responsibility for preparing sections of an EIS, the document is an 
interdisciplinary team effort. In addition, internal review of the document occurs throughout preparation. 
Specialists at the District and State Office levels of the Bureau both review the analysis and supply 
information. Contributions by individual preparers may be subject to revision by other BLM specialists and 
by management during the internal review process. 



Name 

Dick Bonn 



D. F. Buck, Jr. 



L. D. Hamilton 



Primary Responsibility 



Discipline 



Team Leader, Soils, Human Biologist 
Health 



Air, Water, Climate, Geology Soil Scientist 



Technical Coordinator/Editor Geography 



Related Professional 
Experience 

4-1/2 years BLM (Environmental 

Specialist) Portland, Oreg. 

11 years SCS 

2-1/2 years (Biologist) Watershed 

& River basin, Columbus, Ohio. 

2-1/2 years (Biologist) Watersheds 

Richmond, VA. 

4 years (Biologist & Recreation) 
Albany, Oreg. 

2 years (Soil Conservationist) 
Harrisburg, Oreg. 

5 years BLM (Soil Scientist, 
Environmental Protection 



Specialist) 



11 years (Outdoor Recreation 
Planner, Environmental Protection 
Specialist) moved to Colorado, 
March 1982. 



Phillip D. Havens Fisheries & Wildlife 
Jeanne Johnson Editorial Assistant 

R. Michael Martin Socioeconomics 



Wildlife Biology 18 years (Wildlife Biologist) 



Joseph Ross 



Recreation, Cultural 
Resources, Wilderness, Areas 
of Critical Environmental 
Concern, Special Areas, 
Visual Resources and Energy. 



R. Gregg Simmons Description of the Proposed 
Action and Alternatives, 
Vegetation 



Administrative 
Secretary 

Economics 

Recreation 



Forest 
Management 



7 years BLM (Secretary, Editorial 
Assistant 

6 years (Economist) 

8 years (Forestry Technician, 
Biological Information Specialist, 
Outdoor Recreation Planner) 



8 years BLM (Forester) 
5 years Eugene, Oreg. 
3 years Portland, Oreg. 



151 



Roseburg District Personnel Contributing Substantial Input 

Name Primary Responsibility Discipline 



Related Professional 
Experience 



Robert L. Alverts 



Stewart H. Avery 



Robert W. Bright 



Planning coordination, Forest 

information supply, document Management 
review 



Information supply, document Forest Engineering 
review 



Information supply, document Forest 
review Management 



Bennie C. Hobbs Information supply, document Forest 

review Management 



Dennis E. Hutchison Soils, Air, Water information, 
document review 



Joseph B. Lint 



John R. Norlin 



Wildlife information, 
document review 



Forestry information, 
document review 



Resource 
Management (Soil 
Science) 



Wildlife Biology 



Forest 
Management 



Franklin M. Oliver Fisheries information, 
document review 



David R. Palmer 



Robert A. Smith 



Forestry information, 
document review 



Fish Biology 



Forest 
Management 



Information supply, document Forest 
review Management 



16 years BLM (Forester, Area 
Manager, Planning & 
Environmental Coordination) 

7 years Medford 

4 years Burns 

5 years Roseburg 

25 years BLM (Forester, District 
Engineer, Resource Manager, 
Area Manager) 
5 years Medford 

20 years Roseburg 

21 years BLM (Forester, Planning 
Coordinator, Area Manager) 

16 years Roseburg 
5 years Susanville 

13 years BLM (Forester, Timber 
Manager, Area Manager) 

10 years Eugene 

3 years Roseburg 

14 years (10 SCS, 4 BLM) 

8 years Midwest and East 

2 years Idaho 

4 years Roseburg 

8 years BLM (Biologist) 
4 years Coeur 'd Alene 

4 years Roseburg 

25 years (5 BIA, 20 BLM) Forester, 
Timber Manager, Realty Spec, 
Timber Management Spec.) 

3 years Midwest 

2 years E. Wash. 

5 years Tillamook 

15 years Roseburg 

18 years (5 years Oregon 
Department of Fish & Wildlife, 13 
years BLM, Fish Biologist) 
18 years Roseburg 

7 years BLM (Forester) 
7 years Roseburg 

32 years BLM (Forest and Range 
Management, Fire Control, 
Area Manager) 

14 years Alaska 

3 years Burns 

15 years Roseburg 



153 



Appendices 



Page 

Appendix A — O&C Forest Resources Policy to be Used in Developing Plans 

for BLM-administered Forest Lands in Western Oregon 154 

Appendix B — Results of Scoping 1 59 

Appendix C — Development of the Proposed Action and Alternatives 1 65 

Appendix D — Wildlife 1 73 

Appendix E — Alteration of Wildlife Habitat on BLM-administered 

Forest Land 1 79 

Appendix F — Predicted Alteration of Wildlife Habitat on All Forest 

Lands in the EIS Area 1 84 



154 



Appendix A 

O&C Forest Resources Policy 
to be Used in Developing Plans 
for BLM Administered Forest 
Lands in Western Oregon 

This statement sets forth BLM policy for 
management of the Revested Oregon and 
California (O&C) Railroad and reconveyed Coos 
Bay Wagon Road Grant lands situated in the State 
of Oregon. It reflects the provisions of the Act of 
August 28, 1937 (O&C Act), and the effects of 
other relevant legislation and Executive Orders. 

The BLM manages 2.1 million acres of O&C lands 
in western Oregon. The revenues and employment 
generated by timber sales, conversion of timber to 
wood products, and other marketable values 
derived from these lands significantly affect the 
State and local economies. It is further recognized 
that public use of these lands through 
consumptive and non-consumptive recreation, 
including sport hunting and sport and commercial 
harvest of salmon and steelhead produced in 
streams on the O&C lands, also contributes to the 
local and State economies. The primary objectives 
of the management program on the O&C lands are 
to manage for a high-level and sustained yield 
output of wood products needed to contribute to 
the economic stability of the local communities 
and industries, and to provide for other land uses 
as established in the O&C Act and other 
legislation. 

The following principles will guide BLM in 
managing the forest resources on O&C lands: 

1. Resource management plans or management 
framework plans as developed through the land- 
use planning process shall constitute the primary 
guides for carrying out legislative mandates and 
Bureau policies. 

2. All O&C land administered by BLM in western 
Oregon will be classified according to the Timber 
Production Capability Classification. Lands 
classified as suitable for timber production shall 
be managed for timber and wood product 
production, to the extent possible, under the 
requirements of law. Lands classified as 
nonsuitable for timber producton shall be 
allocated to the fullest extent possible to meet the 
needs for non-timber public land uses. Where 
nonsuitable lands cannot adequately provide for 
other uses set forth in the O&C Act and other 
applicable legislation and Executive Orders, 
suitable lands may be managed to meet the needs 
for the following: 

a. Maintenance of water quality in accordance 
with Federal and State standards. Timber 
harvesting may be restricted or excluded only in 



areas where mitigating measures will not maintain 
water quality standards. 

b. Protection of wetlands, including riparian 
zones. Timber harvesting may be restricted or 
excluded only in areas where mitigating measures 
will not be effective. 

c. Conservation of specifically identified habitats 
for federally listed, threatened and endangered 
species. Timber harvesting may be restricted or 
excluded only in areas where mitigating measures 
will not be effective. 

d. Research and development pertinent to the 
management of the land resources. Timber 
harvesting may be restricted or excluded only in 
areas where mitigating measures will not maintain 
resource values, and research is assessing these 
values: timber harvesting may be restricted or 
excluded pending the research conclusions. 

e. Consideration of State goals and objectives 
concerning State-listed, threatened and 
endangered species in land-use planning and 
management. Restrictions may be utilized to 
achieve the habitat objectives developed from the 
BLM plans. 

f. Consideration of habitat needs of native species. 
Restriction of timber harvest may be considered 
when these habitat needs cannot be met through 
established timber harvest practices. 

g. Protection of developed high-value recreation 
areas, including the visual quality of significant 
scenic areas. Restriction or exclusion of timber 
harvest may be considered in the protection of 
established recreation facilities. Timber harvest 
may be restricted in the protection of scenic areas 
only where mitigating measures will not prove 
effective. 

3. The allowable cut determination shall be based 
on a nondeclining harvest level over time. 
Departures from the nondeclining harvest level 
may be permitted in either direction. Any 
increases shall not exceed the long-term 
sustained yield capacity of the land; decreases 
shall be economically and/or biologically justified 
and timed so as to minimize impacts on 
dependent industries and local economies. 

The Serai Stage 
Distribution Concept 

The mid-age and old growth stands remaining 
today are the result of complex interactions 
between plants and animals over time. Evidence 
points towards the simultaneous evolution of 
these plants and animals. Yet, the exact 
functioning and purpose of many of these 
interactions have not yet been studied in depth. 
For example, the mechanisms for nitrogen fixation 
have only been identified within the past decade. 



155 



Additionally, there are indications that mycorrhizal 
inoculation by rodents may be critical to 
plantation establishment and survival in some 
instances (Franklin et al. 1981). There are many 
unknowns regarding which portions of this 
interacting web, if any, must be replicated by 
management if long-term timber production is to 
be maintained at high levels. What is known, 
however, is that the timber management program 
would liquidate the remaining old growth stands 
in a relatively short time if unconstrained. 

Seed zones are accepted as generally 
encompassing a geographic area within which the 
factors affecting reforestation and subsequent 
growth are relatively homogenous. Mid-age and 
old-growth timber in areas allocated to long-term 
timber productivity; habitat for old growth related 
species, including the northern spotted owl; 
riparian habitat; and high scenic quality provides 
adequate coverage of seed zones in the Roseburg 
District (see Appendix C, Modified Area Control). 

For all districts in western Oregon most seed 
zones where old growth currently exists are 
adequately covered. Table A-1 and Figure A-1 
indicate the seed zones which cover the five 
western Oregon district boundaries. 



Table A-1 Tree Seed Zones by 
Elevation in Western Oregon 



Zone 


Elevation 


District 


053 


1,500 


- 2,000 


Salem 


061 


1,000 


- 1,500 


Salem 


061 


1.500 


- 2,000 


Salem 


061 


2,000 


-2,500 


Salem 


062 


500 


- 1,000 


Coos Bay 


062 


500 


- 1 .000 


Coos Bay 


062 


1,000 


- 1,500 


Eugene 


062 


1,000 


- 1,500 


Coos Bay 


062 


1,500 


- 2,000 


Coos Bay 


071 


500 


- 1 .000 


Coos Bay 


071 


500 


- 1,000 


Coos Bay 


071 


1,000 


- 1,500 


Coos Bay 


071 


1,000 


- 1.500 


Coos Bay 


071 


1,500 


- 2,000 


Coos Bay 


071 


1,500 


- 2,000 


Coos Bay 


071 


2,000 


- 2,500 


Coos Bay 


072 


500 


- 1,000 


Coos Bay 


072 


500 


- 1,000 


Coos Bay 


072 


1,000 


- 1,500 


Coos Bay 


072 


1,000 


- 1,500 


Coos Bay 


072 


1.500 


- 2,000 


Coos Bay 


072 


1.500 


- 2,000 


Coos Bay 


072 


2,000 


- 2,500 


Coos Bay 


072 


2,000 


- 2,500 


Coos Bay 


072 


2,500 


- 3,000 


Coos Bay 


072 


2,500 


- 3,000 


Coos Bay 


251 


1,500 


- 2,000 


Salem 


252 


500 


- 1.000 


Coos Bay 


252 


500 ■ 


- 1,000 


Roseburg 


252 


500 ■ 


- 1,000 


Eugene 


252 


1.000 


- 1,500 


Eugene 


252 


1.000 


- 1,500 


Eugene 


252 


1,000- 


- 1,500 


Roseburg 


252 


1.500- 


• 2,000 


Salem 


270 


500 - 


■ 1 ,000 


Roseburg 


270 


1,000 - 


1,500 


Roseburg 


270 


1,000 - 


■ 1,500 


Roseburg 


270 


1,500 - 


■ 2,000 


Roseburg 


270 


2,000- 


2.500 


Roseburg 


270 


2,500- 


■ 3,000 


Medford 


452 


1,500 - 


2,000 


Salem 


452 


3,000 - 


■3.500 


Salem 


452 


3,500 - 


■4,000 


Salem 


461 


1,000- 


1,500 


Salem 


461 


1.500- 


• 2,000 


Salem 


461 


2,000 - 


■2,500 


Salem 


461 


2,500 - 


3,000 


Salem 


461 


3.000 - 


3,500 


Salem 


461 


3.500- 


4,000 


Salem 


462 


1,500- 


2,000 


Salem 


481 


1.500 - 


2.000 


Eugene 


481 


2,000 - 


2,500 


Eugene 


481 


2,500- 


3,000 


Eugene 


491 


500- 


1,000 


Roseburg 


491 


1,000- 


1,500 


Roseburg 


491 


1,500- 


2,000 


Roseburg 


491 


2.000- 


2,500 


Roseburg 


491 


2.500- 


3,000 


Roseburg 


491 


3,000 - 


3,500 


Roseburg 


491 


3,500 - 


4,000 


Roseburg 


492 


1.000 - 


1,500 


Roseburg 


492 


1.500- 


2,000 


Roseburg 


492 


2.000- 


2,500 


Roseburg 


492 


2,500- 


3,000 


Roseburg 


492 


3,000 - 


3,500 


Roseburg 


492 


3.500- 


4,000 


Medford 






051 



053 

S 









U S DEPARTMENT OF THE INTERIOR 




S*\ 




BUREAU OF LAND MANAGEMENT 


052 

R J 




) 
( 





061 




042 



451 



'252 



262 



471 



k 


452 


M 


461 


462 


[463 









L 

052 



472 



071 

North Bend 
Coos Boy 



I 



072 



CO 
O 

081 

o 



082 
090 



®< 



© 



482 



481 



491 

R 10 S E B U R 

!) Roseburg 

492 



512 



FIGURE A-1 
WESTERN OREGON TREE SEED ZONES 



501 



502 



D 







511 



701 D 



721 



Scale 1:1,000.000 



261 Seed Zones Numbers 
^^ Seed Zones Boundary 



159 



Appendix B 
Results of Scoping 
Scoping Meeting 

On October 19, 1981, as part of BLM's land 
use planning process, a public meeting was held 
at the Roseburg District Office to discuss 
important issues and alternatives that should be 
addressed in the Environmental Impact Statement 
(EIS) for the Douglas-South Umpqua Timber 
Management Plan. 

Participants in the meeting suggested 19 different 
alternatives for consideration in the EIS. The 
alternatives suggested, and BLM's analysis of their 
usefulness and relevance to the EIS process, are 
summarized as follows: 

1. Maximum Timber Production. This alternative 
would modify land use Alternative "A" as 
described in the Preferred Land Use Alternative 
Summary brochure, by providing full timber 
harvest in riparian areas and reducing visual 
buffers around recreation areas. It established one 
end of a range of alternatives for analysis in the 
EIS. 

2. Maximum Timber Production Without 
Economic Constraints. This alternative would 
modify Alternative 1 by including all intensive 
timber management practices that are technically 
feasible, whether or not they were cost effective. 
Upon analysis, BLM concluded that all technically 
feasible practices were cost effective and thus 
were automatically included in Alternative 1. 

3. Preferred Alternative Without Old Growth 
Habitat. This would vary from the Preferred by 
including the old-growth habitat (spotted owl 
areas, old growth blocks and 80-acre blocks) in 
the intensive timber management base. This 
defines an analytically useful and relevant land 
use allocation alternative between Alternative 1 
and the preferred alternative. 

4. Preferred Alternative but Include Spotted Owl 
Areas in Allowable Cut Computation. This 
alternative would not permit, during the plan 
period (decade), cutting of the spotted owl areas 
protected in the Preferred; but the allowable cut 
would be calculated as if that land were available 
for timber harvest. This would offer little analytical 
utility as it would simply propose a somewhat 
faster rate of timber harvest on the preferred land 
base, varying all impacts that are strictly 
dependent on the rate of cutting (e.g., economic 
benefits, erosion and sediment yield). 

5. Review Wildlife Mitigating Measures. The thrust 
of this alternative was to obtain a higher timber 
harvest than the preferred alternative by addition 
of measures to mitigate impacts on wildlife with 
less reductions in potential timber harvest. 
Analysis after the meeting led to the conclusion 



that the preferred alternative included all feasible 
measures that would achieve higher timber 
harvest and meet the wildlife goals. 

6. Strong Emphasis on Protection of Natural and 
Cultural Resources. This would be similar to 
Alternative "D" in the Preferred Land Use 
Alternative Summary Brochure, but modified to 
exclude intensive forest management practices 
which enhance timber yield. This includes 
protection of a variety of wildlife habitats, sensitive 
botanical species, cultural resources, visual 
resources, research natural areas, riparian areas 
and undeveloped recreation activities and 
facilities. 

Approximately 263, 700 1 acres of commercial 
forest land would be managed on a 60-year 
minimum harvest age, although no intensive 
management practices which enhance timber 
yield would be applied to harvested areas after 
planting. Fifteen year spacing between harvest 
areas would be employed. An additional 127,400 
acres of commercial forest land would be 
withdrawn from the allowable cut base to protect 
the resources listed above. Harvest from these 
areas would be allowed only when directly 
benefitting the protected resources. 

7. Full Ecosystem. This alternative is intended to 
emphasize the allocation of land for protection of 
wildlife habitat diversity and related values. 
Alternative 6 encompasses this approach. 

8. Maintain Old-Growth Dependent Species and 
Non-Declining Yield of Resources Other Than 
Timber. Alternative 6 basically would achieve this 
objective. 

9. Limit Timber Management to Existing 
Developed Land to Maintain Wildlife Habitat and 
Watershed Protection. Alternative 6 would also 
basically achieve this objective. 

10. No Timber Harvest. This alternative would not 
in any way meet the primary objective of the 
timber management plan—providing a sustained 
timber harvest. In addition, this alternative 
received only limited support at the public 
meeting. 

11. The Natural Situation Before BLM Land 
Management Began. This is not a realistic 
alternative as no BLM management could 
reestablish this situation. In addition, this 
alternative received only limited support at the 
public meeting. 

12. Departure From Even Flow. This suggestion 
assumed that first-decade departure from even- 
flow would not cause a subsequent decline below 
the even-flow level, for either the preferred land 
base or the land base in Alternative 1 . BLM 
analysis has shown, however, that it is not 
possible to depart from even-flow in the first 

1 Refinement since the scoping meeting has resulted in the following 
breakdown for the constrained timber production base: 



160 



decade without causing a subsequent decline 
below the even-flow level. Thus, the alternative is 
not viable. 

VRM (MHA-130) 49,376 

Wildlife (MHA- 60) 107,180 

Wildlife (MHA -250) 83,211 

Wildlife (MHA -350) 22,669 

13. Lower Average Minimum Harvest Size. This 
alternative is identical to the preferred alternative 
except that minimum harvest size and 
corresponding minimum harvest age would be 
reduced. The minimum average tree diameter in 
stands selected for final harvest would be 1 1 
inches diameter breast height (dbh) compared to 
14 inches dbh under the preferred alternative. The 
equivalent minimum harvest age would be 40 
years instead of 50 years as in the preferred 
alternative. This alternative is considered to be 
analytically useful to the decisionmaker. 

14. A Constant Budget. This alternative would be 
expected to show whether, in the long run, a 
constant budget would support the increasing use 
of intensive management practices planned in the 
Preferred Alternative. For the other alternatives, a 
constant budget is assumed for the short term (10 
year), but analysis of the long-run implications 
would require making economic assumptions 
extended over a time span of at least 60 years (the 
time by which old growth on lands in intensive 
management would be harvested). Such long-term 
economic forecasts would be too conjectural to be 
useful to the decisionmaker; however, a constant 
dollar long-term budget will be displayed for the 
preferred alternative. 

15. Use of Different Computer Model for Allowable 
Cut Computation. This is a relevant suggestion 
which will be investigated for application to the 
next cycle of allowable cut determinations, which 
will begin in several years. At this stage of the 
current process it is not practical for BLM to 
obtain a different computer program for allowable 
cut computations. 

16. Economic Optimum for Timber Management. 
This suggestion focused on management like that 
of an industrial forest, with a goal of at least 7 
percent real return on investment. The Bureau's 
planning process is not oriented to defining such 
an alternative, but the revenues and costs of 
timber management for the preferred alternative 
will be defined in the EIS. 

17. Departure from Even-Flow on the Preferred 
Land Base, with a Constant Budget. This would 
combine Alternatives 12 and 14, which as 
previously stated, are not viable or practical. 

18. No Fertilization, No Herbicides, No Credit for 
Genetically Improved Trees. This alternative 
would exclude the use of both fertilizer and 
herbicides for timber management. It would 
provide for continued planting of genetically 



improved trees, but the allowable cut computation 
would not take credit for expected growth 
increases. It is a relevant and useful alternative to 
analyze. 

19. No Fertilization, No Credit for Genetically 
Improved Trees. This alternative would differ from 
Alternative 18 only in one dimension. It would not 
be analytically useful to include it in addition to 
No. 18. 

The above analysis concludes that five alternatives 
suggested at the meeting were relevant and useful 
to analyze in addition to the preferred alternative 
and the No Action (continue existing 
management) Alternative. These seven 
alternatives display five land use bases; however, 
only one (Alternative 6) represents a land use 
allocation with an allowable cut level lower than 
the preferred alternative. For comparative 
purposes, another land use allocation alternative, 
with an allowable cut level below the preferred 
alternative, should be included. Alternative C, 
described in the Preferred Land Use Alternative 
Summary Brochure, fills this need. 

The preceding summary, although organized 
differently, was discussed with the Roseburg 
District Multiple Use Advisory Council on October 

20, 1981. The Council concurred with BLM's 
review of the alternatives and the recommended 
number for analysis in the EIS. There was a 
suggestion to include an additional alternative that 
would allocate only the best timber producing 
lands to intensive timber management, leaving the 
remainder to provide benefits for wildlife, water 
quality, visual quality and other resources. This 
approach, although not supported by the majority 
of the Council, was later analyzed by BLM. In the 
development of the preferred alternative, this 
approach had already been adopted to the extent 
possible. Its utility for meeting wildlife and related 
objectives is quite limited, however, as the most 
productive timber land also has the highest 
productivity for certain wildlife species. 

Based on the public comments, BLM analysis and 
District Advisory Council recommendations, we 
have concluded the EIS should analyze the 
following alternatives: 

1. Maximum Timber Production (Discussion Item 

1) 

2. Emphasis On Timber Production (Discussion 
Item 3) 

3. Lower Minimum Harvest Size (Discussion Item 
13) 

4. Proposed Action 

5. No Action 

6. Minimum Necessary Habitat Diversity 
(Alternative C in Summary Brochure) 

7. No Herbicides, Fertilizer or Allowable Cut Effect 
for Genetics (Discussion Item 18) 

8. Emphasis on Protection of Natural and Cultural 
Resources (Discussion Item 6) 



161 



The public, through the EIS scoping, did an 
excellent job of defining a number of issues they 
believed the EIS should address. 

Analysis showed that most of the issues fell within 
the broad range of issues listed in the handout 
used to begin the discussion at the EIS scoping 
meeting. Following is a revised list of issues to be 
discussed in the EIS. These are environmental 
values which could be significantly impacted by 
the timber management proposal or other 
alternatives as seen by the public: 

Air Quality - smoke management 

Soils - fragile areas; erosion potential 

Water - quality and quantity; impacts from 
intensive management practices; municipal 
watersheds; rural and domestic watersheds; 
impact of adjoining landowners. 

Vegetation - threatened and endangered species, 
consistency with Endangered Species Act; 
riparian, consequences of different protection 
levels; old growth, amount and distribution; 
consequences of herbicide use compared with 
other vegetation management alternatives. 

Fish and Wildlife - threatened and endangered 
species, consistency with Endangered Species 
Act; habitat diversity, impacts of intensive 
management practices, difficulties/opportunities 
in mixed land pattern, consequences of different 
minimum harvest ages; nongame species, species 
list, abundance, distribution, snag retention policy 
by alternative; big game species and anadromous 
fish, impacts of roads, impacts of cover removal, 
impacts of intensive management practices; 
northern spotted owls, decadal population levels, 
possible listing as threatened/endangered species, 
impacts of intensive management practices; 
schedule of mitigating or enhancing practices; 
consideration of non-suitable timberland for 
allocation to wildlife; corridors, objectives, 
benefits, consequences. 

Social Conditions - consideration of adjoining 
landowners. 

Economic Conditions - public revenue; personal 
income; employment; dependent communities; 
funding mechanisms; benefit/cost relationships; 
opportunity costs of management strategies. 

Recreation - economic basis for recreation 
opportunity, including hunting and fishing. 

Visual Resources - difficulties/opportunities in 
mixed land pattern; consideration of adjoining 
landowners. 

Cultural Resources - protection of sites 

Human Health - impacts of herbicides 

Areas of Critical Environmental Concern (ACECs) 



Intensive Forest Management Practices - genetic 
tree improvement; use of different silvicultural 
systems; consideration of non-suitable forestland 
for other uses; volume contribution of intensive 
practices; limitations on size and timing of 
clearcuts; description of current intensive 
practices and proposed practices; description of 
allowable cut calculations; display of yield 
equations. 

Several topics were surfaced as issues for 
discussion. Although monitoring was suggested 
as an issue, it is not practical to develop a realistic 
monitoring plan for each alternative in the EIS. A 
full monitoring plan will be developed and 
included as an appendix to the decision document 
to be prepared after completion of the EIS. 

Some additional aspects of economic analysis 
were suggested. It is felt that the topic list under 
economics is a broad framework and other items 
suggested as economic issues are encompassed 
within this framework. 

Near the end of the meeting, the audience was 
asked for its preference on meetings which could 
be held during the public comment period on the 
draft EIS. An unstructured public meeting and/or 
a formal hearing were offered for discussion. The 
response favored both kinds of sessions, although 
opinions were mixed on the issue. A portion of the 
group preferred no meetings at all, remarking that 
written comments should be more than adequate. 

Scoping Correspondence 

Subsequent to the discussion of alternatives 
with the Roseburg District Multiple Use Advisory 
Council, two letters were received. One letter 
suggested an alternative which assumes the 
average management intensity and departs above 
the long-run sustained yield (LRSY). Although the 
LRSY would be substantially lower than for other 
alternatives, there would be surplus old growth 
volume permitting harvest above LRSY. Under the 
intensity of management in the preferred 
alternative there would be no available surplus 
volume. Surplus volume may be created by using 
the above suggested assumptions which constrain 
the sustainable harvest level. Including an 
alternative in the EIS to "create" surplus inventory 
in such a way was not considered useful enough 
analytically, or to the decisionmaker, to warrant 
the resultant increased complexity of the EIS. 

The other letter proposed a departure alternative 
that would increase the annual sale program in the 
first two or three decades after which the harvest 
level would be allowed to drop by no more than 5 
percent below the even-flow level. It suggested 
that this analysis be applied to the maximum 
timber land base (Alternative 1), the maximum 
timber base with provisions for spotted owls 
(Alternative 2) and the preferred alternative land 
use allocation (Alternative 4). 



162 



Although it is interesting to analyze the effects of 
these three alternatives on harvest levels, 
inclusion of them as full alternatives in the EIS 
would make the EIS very cumbersome and add 
little dimension to the analysis of impacts other 
than socioeconomic impacts. Accordingly, they 
are not included in the EIS, but the resultant 
harvest levels have been computed. The annual 
timber sale programs (using a two decade 
increase with a 5 percent decline below the 
evenflow level in succeeding decades) are shown 
below in million board feet: 



Decade 



Alt. 1 



Alt. 2 



Alt. 4 



1 


329 


303 


283 


2 


329 


303 


283 


3+ 


274 


254 


237 



Economic Efficiency Discussion 

During the EIS scoping process four economic 
analyses were requested by members of the 
public. The DEIS presented four different looks at 
the Original Proposed Action (Alt. 4) from an 
economic perspective. In response to comments 
received, these analyses are expanded where 
clarity was lacking in the DEIS and abbreviated 
where a summary of findings would suffice. The 
substantive change is to supplement projections 
of growth rates in the value of timber adjusted for 
inflation with two baseline price levels. The 
average sales value of timber on the Roseburg 
District in Fiscal Year 1981 (FY 81) was $260 per M 
bd. ft. The average value for fiscal year 1982 was 
$94 per M bd. ft. 

Economic Efficiency of the Timber Management 
Program in the New Preferred Alternative (Alt. 9). 

The timber management programs in both the 
Original Proposed Action and the Preferred 
Alternative would yield $6.72 in timber sale 
receipts for every dollar of costs at the FY 81 sales 
value of $260 per M bd. ft. Each program would 
yield $2.43 in timber sale receipts for each dollar 
spent at the FY 82 sales value of $94 per M bd. ft. 
Table B-1 identifies for Alternatives 4 and 9 the 
annualized costs of major program elements for 
fiscal years 1984-93. The district's proposed 
budget for FY 83 is displayed for reference. 
Recognize two important facts when comparing 
budgets in the alternatives with dollars 
programmed for FY 83. Since BLM has accepted 
responsibility for prescribed burning on the 
district lands, fire management costs will increase 
substantially (with any alternative) in the new plan 
over the amount budgeted for FY 83. Similarly, 
timber management costs rise beginning in FY 84 
even if programmed output is held constant 
(Alternative 5). This reflects the fact that the 
district in 1984 would have a larger percentage of 
its land base receiving more levels of management 
than it did in 1972. Determining allowable cut 
levels decade by decade causes discrete jumps in 



management requirements to occur with each new 
allowable cut declaration. If the FY 83 budget is 
maintained for the decade, the sustainable output 
is estimated to be 184 MM bd. ft. per year. 

Economic Efficiency of the Forest Management 
Practices in the New Preferred Alternative (Alt. 9). 

Commercial forest land in the Roseburg District is 
managed under the principle of sustained yield. 
The thrust of the district's forestry program is to 
achieve economic and silvicultural efficiency and 
environmental protection consistent with a high 
level of annual or regular periodic output of 
timber. The district has developed a forestry 
program for its Management Framework Plan 
(MFP). Among other goals, the selected forestry 
program targets a package of management 
practices which, ultimately, would be applied to 
most acres on the district's commercial forest 
land. Practices chosen by the district include tree 
improvement through genetic selection, spacing 
management (precommercial and commercial 
thinning) and fertilization. This was the set of 
practices which the district found to be technically 
and environmentally feasible. This section 
contrasts the economic payoff of the complement 
of practices adopted in the Preferred Alternative 
with other possible management combinations. 

Research has established that, at the margin, each 
of these practices yields a favorable ratio of 
discounted dollar benefits to discounted dollar 
costs when applied to forests which are managed 
under sustained yield and have an abundance of 
mature timber (allowable cut effect; see Beuter 
and Handy 1974 and Hoyer 1975). Increasingly, as 
the ratio of mature to immature timber declines, 

Table B-1 Cost of Forest Management 
in the New Preferred Alternative 
(Alt. 9) and Original Proposed Action 
(Alt. 4). 



Major Program Area 
Affecting Timber Harvest, 
Reforestation and Growth 

Transportation Systems' 
Timber Management 
Fire Management 2 
Wildlife 
Soil/Air/Water 

Total 



Annual Cost in 
Thousands of Dollars 



Alt. 4 


Alt. 9 


FY 1983 


OPA 


NPA 




$1,696.6 


$1,683.0 


$1,134.9 


7,174.8 


7,120.9 


5,176.7 


529.4 


525.1 


183.3 


128.0 


128.0 


110.0 


100.0 


100.0 


94.0 



$9,628.8 $9,557.0 $6,698.9 



1 This category does not include funding for bridges, road and 
aggregate production projects handled through the Federal 
Highway Administration Funding for these projects is held at the 
State Office. An estimated $500,000 is needed for these con- 
struction projects. 

2 Program areas directly related to reforestation and growth. 



the significance of an allowable cut effect 
dwindles. The district's target is a package of 
practices which is economically efficient both now 
and in future decades where there is no allowable 
cut effect (as early as the fifth decade under the 
Alternatives 1 through 5 and 9). The district 
analyzed packages of practices by soil 
expectation value per acre, where soil expectation 
value is defined to be the value today of initiating 
a management program on a nonstocked acre and 
maintaining that program throughout the future. 
Soil expectation values net discounted dollar 
costs from discounted dollar returns. For 
comparability, each complement of practices is 
applied to average site conditions on the 
Roseburg District (the Bureau's allowable cut 
modeling is based on the average site conditions 
in each sustained yield unit). Soil expectation 
values are ranked using discount factors net of 
inflation of 4 percent, 7.625 percent and 10 
percent per year. The 4 percent rate is the factor 
by which the U.S. Forest Service discounts future 
returns and costs of forest management to 
determine an equivalent value in today's dollars. 
Their analysts argue that a 4 percent return net of 
inflation is comparable to the yield on new long- 
term investments in the private sector (Row et al. 
1981). They also argue that the value of timber will 
appreciate 1.65 percent per year faster than 
general inflation for 50 years (Haynes et al. 1980). 

Table B-2 summarizes the district's findings. 
Arrayed are packages of practices which 
maximize soil expectation value at various 
discount rates and possible levels of price 
appreciation. 

Table B-2 Package of Practices 
Which Maximizes the Soil Expectation 
Value of Roseburg District Acres 
Reforested 1984-1993 at Various 
Discount Rates and Levels of Price 
Appreciation 



163 

Budget and Revenue Implications of the New 
Preferred Alternative (Alt. 9). 

When measured in constant dollars, the 
budget requirements of the Preferred Alternative 
increase through the first four decades and then 
steadily decline in the fifth through 14th decades 
(Table B-3). The trend in revenues is tied to both 
the long-term changes in the value of timber and 
the type of timber BLM will offer in the future. 
Today, in second-growth management, log values 
and logging costs are sensitive to the average 
diameter and volume harvested per acre (Sessions 
1979). Each of the alternatives yields a diameter 
size class to harvest acres to decade relationship. 
Table B-3 reports prospective revenues by decade 
for three possible combinations of base price and 
appreciation in the value of timber (adjusted for 
inflation). The table addresses questions raised by 
members of the public in the EIS scoping process. 
Some participants felt that the costs of the timber 
management program in future decades may well 
exceed revenues. The column in Table B-3 labeled 
net return indicates that total revenues of the 
Preferred Alternative will exceed total costs in 
future decades at $260/M bd. ft. and where timber 
values are increasing. The revenues would be the 
amounts distributed to counties and the federal 
treasury. 



Discount 




Rate 


4% 


Increase in 




the Value of 




Timber 




1981 Price level 


Plant Improved 


of $260/M 


Stock, Final 


bd. ft 


Harvest 



1.65 Annual 
Price Apprecia- 
tion 1981-2030 



1 65 Annual 
Price Apprecia- 
tion 1981 
Forward 



Plant Improved 

Stock, 

Precommercial 

Thin, 

Fertilize, 

Final Harvest 

Plant Improved 
Stock, Precom- 
mercial Thin. 
Fertilize, Com- 
mercial Thin, 
Final Harvest 



7.625% 



Plant Improved 
Stock, Final 
Harvest 

Plant Improved 
Stock, Final 
Harvest 



Plant Improved 
Stock, Precom- 
mercial Thin. 
Fertilize, Com- 
mercial Thin, 
Final Harvest 



10% 



Plant Improved 
Stock, Final 
Harvest 

Plant Improved 
Stock. Final 
Harvest 



Plant Improved 
Stock, Precom- 
mercial Thin, 
Fertilize, Final 
Harvest 



164 



Table B-3 Decadal Budget Requirements and Prospective Revenues of the 
New Preferred Alternative (Alt. 9) 
(millions of 1980 dollars) 











Revenues @ 






Net Return 










1.65% 






@ 1 .65% 










Annual 






Annual 










Increase 






Increase 










in Timber 






in Timber 




Budget Re- 


Revenues at 


Revenues at 


Values 


Net Return 


Net Return 


Values 


scade 


> quirements 


$94/MBF 1 


S260/MBF' 


1980-2030 


at $94/MBF at S260/MBF 


1980-2030 


1 


95.60 


232.18 


642.20 


723.84 


136.58 


546.60 


628.24 


2 


87.04 


221.78 


613.43 


820.26 


134.74 


526.39 


733.21 


3 


101.19 


204.50 


565.65 


897.33 


103.31 


464.46 


796.14 


4 


109.06 


173.75 


480.60 


929.37 


64.69 


371.54 


820.31 


5 


94.80 


72.87 


201.55 


699.83 


-21.93 


106.75 


605.03 


6 


86.13 


84.44 


233.56 


730.39 


-1.69 


147.43 


644.25 


7 


90.01 


70.55 


195.14 


719.18 


-19.46 


105.13 


629.17 


8 


89.33 


72.04 


199.25 


723.05 


-17.29 


109.93 


633.72 


9 


84.99 


68.44 


189.32 


698.44 


-16.55 


104.32 


613.45 


10 


83.62 


71.87 


198.78 


729.10 


-11.76 


115.15 


645.47 


11 


83.39 


82.54 


228.31 


789.51 


-0.85 


144.91 


706.11 


12 


79.17 


90.28 


249.71 


828.39 


11.11 


170.54 


749.22 


13 


75.98 


99.37 


274.85 


885.13 


23.39 


198.87 


809.15 


14 


69.25 


109.77 


303.61 


942.37 


40.52 


234.36 


873.12 



'Revenues per M bd. ft. are adjusted by the average diameter of harvest and the average volume per acre and based on current 
experience and utilization standards. 



165 



Appendix C 

Development of the Proposed 

Action and Alternatives 

Defining the proposed action is the last 
phase of the planning process prior to preparation 
of the EIS. Alternatives to the proposed action are 
identified during the scoping phase of the 
environmental analysis process. Each alternative 
analyzed in this EIS contains a mix of variables 
encompassing a range of choices for 
decisionmakers as required by the CEQ 
Regulations (40 CFR 1502.2 (2)). 

In determination of a sustained yield allowable 
cut, the primary variables are land classification, 
acres allocated to timber production and 
enhancement of growth assumed from specific 
development practices or treatments. Following in 
the order of occurrence are brief descriptions of 
the inventories and processes employed to 
determine the allowable cut level for the proposed 
action and each alternative. 

Land Classification and Inventory 
Timber Production Capability 
Classification 

The Timber Production Capability 
Classification (TPCC) is an intensive inventory 
process initiated in 1972 to categorize all public 
land administered by BLM in western Oregon 
based upon the land's physical and biological 
capacity to produce timber. TPCC was conducted 
in accordance with Oregon Manual Supplement 
5250. 

The TPCC identified 402,000 acres of commercial 
forest land which could be managed on a 
sustained yield basis. Approximately 10,900 acres 
of the commercial forest land were determined to 
be incapable of undergoing harvest without 
significant site degradation. These lands, 
excluded from the timber production base, were 
placed in this category when it was judged that 
economically reasonable technology was not 
available to mitigate such degradation. The 
remainder of the SYUs' 21,900 acres was 
determined to be non-forest or non-commercial 
forest. If new data become available from intensive 
on-site analysis or improvements occur in 
technology, the classifications may be altered. 

Operations Inventory 

For BLM to carry out the timber management 
program effectively, specific information as to the 
location and current condition of the various 
forest types within the land base must be available 
to the managers. This is accomplished through 
the Operations Inventory (Ol) in accordance with 
procedures contained in the Operations Inventory 
Handbook (STORMS). 



The Ol is an intensive inventory providing forest 
type maps which show the location and 
classification of each homogeneous forest type 
island. Ol record cards list acreage, silvicultural 
needs and opportunities for application of forest 
management practices on each type island. 
Operations Inventory thus provides a basis for 
establishing priorities for treatment based on 
stand conditions and productivity. 

1978 Forest Reinventory 

A reinventory of commercial forest land in 
the SYUs was completed in 1978 employing 
procedures for extensive inventory jointly 
developed by the USFS and BLM (USDA, FS 
1976). The reinventory uses the same basic 
inventory design as was used for determination of 
the present allowable cut, but with further 
refinement to include stratification of commercial 
forest land based on information obtained from 
the Ol and TPCC. Statistical analysis indicates the 
sample mean volume per acre in the Roseburg 
SYUs is within 8 percent of the true mean volume 
per acre at one standard deviation. 

The reinventory indicates a forest distribution as 
displayed in Table C-1. Age classes range from 
non-stocked, where reproduction has not been 
established, to 500 years. 



Table C-1 Existing Acres by Age 
Class on All Forest Lands 



Age 




Age 




Class 


Acres 


Class 


Acres 


Non- 








stocked 


7,403 


210 


5,849 


1-5 


26,740 


220 


5,649 


10 


40,853 


230 


25,085 


20 


36,568 


250 


12,291 


30 


13,852 


260 


4,348 


40 


5,973 


270 


1,504 


50 


9,065 


280 


2,294 


60 


11,319 


290 


1,301 


70 


8.959 


300 


13,799 


80 


10,931 


310 


6,882 


90 


11,741 


320 


2,294 


100 


13,282 


340 


2,294 


110 


16,879 


350 


2,294 


120 


20,008 


380 


4,588 


130 


3,595 


390 


2,294 


140 


3,595 


400 


2,294 


150 


10,545 


410 


2,294 


160 


5,616 


470 


2,294 


170 


6,197 


490 


742 


180 


21,947 


500 


6,882 


190 


8,305 






200 


3,592 


Total 


404,236 



166 



Other Resource Inventories 

Inventories were conducted to identify and 
categorize specific capability and potential of 
resources other than timber. Recreation planners 
applied the BLM's Recreation Information System, 
an inventory approach for determining inherent 
potential of the land to support various recreation 
activities. Visual resource specialists inventoried 
and classified the SYUs for visual and esthetic 
considerations. A review and compilation of 
known cultural resource data (Class I cultural 
resource inventory) has been completed. Wildlife 
biologists inventoried northern spotted owl and 
bald eagle nest sites. Fisheries biologists 
conducted surveys of streams within the district. 
Botanical surveys for threatened and endangered 
plants were initiated for the Roseburg District in 
September 1978 and are updated yearly. A 
district-wide soil inventory was completed by Wert 
et al. 1977 (see References Cited). 

Criteria for Selecting the Original 
Proposed Action (Alternative 4) 

The following criteria were used by the 
District Manager in developing the Original 
Proposed Action: 

• Meet the long-term objective to attain a high 
level of sustained yield timber production to 
satisfy regional and national needs. 

• Minimize soil loss caused by both management 
activities and uncontrolled activities (e.g., off-road 
vehicles). 

• Contribute to the improvement or maintenance 
of water quality in streams, rivers and municipal 
watersheds, compared to current conditions. 

• Minimize sediment reaching the stream and 
water temperature changes that occur as a result 
of management activities. 

• Minimize impacts on air quality in residential 
areas. 

• Provide for developed and dispersed 
recreational opportunities to meet demands 
related to BLM-administered lands. 

• Provide for maintaining the visual quality of the 
forest landscape in areas of high sensitivity. 

• Protect or improve and develop fish spawning, 
rearing and migration habitat. 

• Protect important wildlife habitat. 

• Protect or enhance habitat of threatened or 
endangered plant and animal species. 

• Provide for scientific and educational study 
through such programs as Research Natural 
Areas. 



• Allow minerals exploration and development 
while protecting other resource values. 

• Allow adequate land allocations for 
communication sites, access development and 
designation of right-of-way corridors while 
protecting other resource values. 

• Provide local economic stability through high 
levels of local employment and personal earnings 
which are dependent on raw materials, recreation 
and other use opportunities available on lands 
administered by BLM. 

• Provide for a high level of contribution to local 
public revenues from resources and activities 
available on public lands. 

• Demonstrate consistency with State planning 
goals (Land Conservation and Development 
Commission), acknowledged local comprehensive 
plans, and officially approved local resource 
related plans, programs and policies. 

• Demonstrate consistency with other Federal 
resource-related plans, programs, and policies. 
(Provide coordinated approach to regional issues 
and projects or proposals crossing administrative 
lines.) 

Land Use Allocation 

During the development of the proposed land 
use allocations, broad land use alternatives (MFP 
Alternatives) were identified and reviewed by the 
District to assess their effects. These MFP 
alternatives were circulated for public review and 
comment in 1981. Scoping (see Appendix B) of 
the EIS led to the conclusion that four of these 
land use allocation alternatives (some slightly 
modified) were important enough to analyze in 
depth. The resulting land use allocations by 
alternative (Table C-2) were adapted from those 
alternatives. Alternatives 1, 4, 6 and 8 of the draft 
EIS were adapted from these alternatives. 

Resource protection varies by alternative relative 
to the mixture of land use allocations and 
management features prescribed. Table C-3 
shows acreage allocations, by resource, of the 
MFP withdrawals and constrained timber 
production bases. Table C-4 identifies proposed 
management features applied during management 
of the timber producing lands relative to the level 
of protection provided by each alternative. 

When final MFP timber management decisions are 
made, they will form the management 
prescriptions. Similarily, actions for other 
resources, e.g., habitat management plans, will be 
within the MFP guidelines. 



167 



Table C-2 Land Use Allocation Proposed for the EIS Alternatives (Acres) 



No Planned Timber Harvest 

Non-Commercial Forest Land 
Non-Forest Lands 
Fragile Site Withdrawals 
Reforestation Withdrawals 
MFP Withdrawals 2 



Alt. 1 


Alt. 2 


Alt. 3 


Alt. 4 


Alt. 5' 


Alt. 6 


Alt. 7 


Alt. 8 


Alt. 9 


Max. Tbr. 


Emp. Tbr. 


LoMHS 


OPA 


No Action 


HD 


No Herb. 


Full Eco. 


NPA 



2,259 



2.259 



2,259 



2,259 



14,304 



2,259 



2,259 



2,259 



2,259 



19,660 


19,660 


19,660 


19,660 


18,204 


19,660 


19,660 


19,660 


19,660 


2,614 


2,614 


2,614 


2,614 





2,614 


2,614 


2,614 


2,614 


8,293 


8,293 


8,293 


8,293 





8,293 


80,421 


8,293 


8,293 


4,448 


5,704 


5,704 


5,704 


404 


48,790 


5,704 


128,634 


23,565 



Sub-total 



37,274 



38,530 



38,530 



38,530 



32,912 



81,616 110,658 161,460 



56,391 



Planned Timber Harvest 

Intensive Base 



Constrained Base 

VRM 

Wildlife 



386,622 


360,580 


333,319 


333,319 


377,098 


222,357 


261,191 





331.637 





3,682 


2,646 


2,646 


5,812 


31,345 


2,646 


49,376 


2,658 





21,104 


49,401 


49,401 


8,074 


88,579 


49,401 


213,060 


33,210 



Sub-total 

Total SYUs Acres 



386,622 385,366 385,366 385,366 390,984 342,281 313,238 262,436 367,505 
423,896 423,896 423.896 423,896 423,896 423,896 423,896 423,896 423,896 



1 Land use allocations for Alternative 5 (No Action) resulted from the land classification instructions used in the 1970 planning 
process. For example, fragile sites and reforestation withdrawal are contained in the non-commercial forest land category. 

2 These are commercial forest lands withdrawn from the timber production base for other resourc considerations. See Table C-3 
for the identified resource and acres allocated. 



Table C-3 Acreage Allocation by Resource 



Alt. 1 
Max.Tbr. 


Alt. 2 
Emp. Tbr. 


Alt. 3 
LoMHS 


Alt. 4 
OPA 


Alt. 5 
No Action 


Alt. 6 
HD 


Alt. 7 
No Herb. 


Alt. 8 
Full Eco. 


Alt. 9 
NPA 


611 
508 
502 


611 

508 

1,185 


611 

508 

1,185 


611 

508 

1,185 






404 


570 

508 

2,773 


611 

508 

1,185 


570 

508 

4,615 


611 

508 

1,185 


2,912 






2,912 

640 








2,912 

640 








2,912 

640 















2.769 

1,280 

21,422 

26,383 




2,912 

640 










2,560 

40,098 

90,707 




2,699 

640 



18.332 





Resource Considerations in 
Acres * 

MFP WITHDRAWALS 

Botanical 

Cultural 

Recreation 1 

Wildlife: 
Bald Eagle 

Golden Eagles & Raptors 
Old Growth Blocks 
Riparian Areas 
VRM II 

CONSTRAINED TIMBER PRODUCTION 
BASE 

Visual Resource Management 

Wildlife: 
Bald Eagle 

Northern Spotted Owl 
Old Growth Blocks 
80 Acre Blocks 
Osprey 
Riparian Areas 

"Acres are not additive due to overlap. 

' Includes developed sites, recreation facilities, research natural areas, outstanding natural areas and in Alternatives 6 and 8 sites 
pending suitability studies. 



8,383 



8,383 



8,383 



5.812 



45,703 



8,383 



90.703 



8.383 
























8.769 











19,826 


19,826 





27,407 


19,826 


54,940 


20.321 








14,700 


14,700 








14,700 





16,780 








10,582 


10,582 





67,727 


10,582 


102,466 


11,370 





3,445 


3,445 


3,445 





5,273 


3,445 


10,430 


3.058 





18,332 


18,332 


18,332 


8,074 





18,332 









168 



Table C-4 Management Features 



Resource Feature 



WILDLIFE 


AIM 


All. 2 


Alt. 3 


Alt.4 


Alt. 5 


Alt. 6 


Alt. 7 


Alt. 8 


Alt. 9 




Max. Tbr. 


Emp. Tbr. 


Lo MHS 


OPA 


No Action 


HD 


No Herb. 


Full Eco. 


NPA 


Riparian Zones 


No timber 


No restriction 


Same as »2 


Same as #2 


No harvest 


No harvest 


Same as »2 


Complete 


No harvest 




harvest 


on 1st and 2nd 






restriction on 


restriction on 




protection on 


restriction on 




restrictions 


order streams. 






1st and 2nd 


1st and 2nd 




all stream 


1st and 2nd 






Approximately 






order streams 


order streams; 




orders, totaling 


order streams. 






18.300 acres 






An estimated 


an estimated 




approximately 


an estimated 






along 3rd order 






8,070 acres 


26,400 acres 




90.700 acres. 


18.300 acres 






and larger 






along 3rd order 


along 3rd order 






along 3rd order 






streams would 






and larger 


and larger 






and larger 






be managed 






streams would 


streams would 






streams would 






under modified 






receive 


receive 






receive 






area control. 






protection. 


complete 






complete 






Harvest is 








protection 






protection. 






expected to 




















occur on an 




















estimated 6% 




















of this area, of 




















which 11% 




















would be 




















clearcut. 

















Snags (#/acre) 



Northern 
Spotted Owls 

Managed for 

(pairs) 



None on 6/acre in 

intensive modified area 

timber base control 3/ac. 

6/acre on other on remainder 
forest lands 



Same as #3 



Non on 
intensive base 
3/ac. on other 
forest land 



2/acre on 25% Same as #3 

of intensive 

outside of old 

growth areas 

3/ac on old 

growth and 

other land with 

no planned 

timber harvest. 



25 



3/acre on 35% Same as #3 

of land base 

outside of old 

growth areas. 

3/acre on old 

growth and 

other lands 

with no 

planned timber 

harvest. 



55 



19 



Spacing 
Between 
Clearcuts (year) 



3-5 



3-5 



5 year on 
intensive base 
variable in 
modified area 
control 



Same as #3 



3-5 



10 



Same as #3 



Same as #3 



Modified Area 
Control (acres) 







24,800 


52.050 


52,050 










52.050 





35.868 


RECREATION 
























Potential 
Recreation 
Sites (#) 


3 




12 


12 


12 







8 


12 


8 


12 


Natural Areas 
(potential) (#) 
(designated) (#) 



2 




6 
2 


6 
2 


6 
2 



2 




6 
2 


6 

2 


6 
2 


6 
2 


Areas of Critical 
Environmental 
Concern 
(number/acres) 


4/600 


4/2.100 


4/2.100 


4/2,100 







8/3,100 


4/2.100 


8/3.100 


4/2,100 


Visual Resource 
Management 
Classes (acres) 

I 

II 

III 

IV 


30 

2.400 

400 

421.170 


30 

9.300 

13.600 

401.070 


30 

9.300 

13,600 

401,070 


30 

9.300 

13.600 

401.070 


30 

1.100 

3,000 

419.870 


30 

26,600 

22,400 

374.970 


30 

9.300 

13.600 

401.070 


30 

75,700 

22,900 

325.370 


30 

30 

13.600 

401,070 



169 



Modified Area Control 

Modified area control is a process for 
managing a given number of acres under a special 
timber harvest regime. In the Roseburg District, 
52,047 acres are proposed to be managed under 
the modified area control concept for Alternatives 
3, 4 and 7, 35,868 acres for Alternative 9 and 
24,786 acres for Alternative 2. Harvest methods 
and volumes will vary, ranging from clearcut to 
individual tree selection, depending on the 
particular resource involved, the degree of 
protection necessary and the silvicultural system 
used. 

Although in practice not every area would be cut, 
for purposes of calculating allowable cut yields, it 
was assumed the entire acreage would be 
managed oh a 250 year harvest age. The volume 
to be harvested during the first decade under this 
concept was calculated manually, and the result 
was tested using SIMIX to ensure sustainability. 
Approximately 9 MM bd. ft. would be scheduled 
for harvest from these areas each year, except in 
Alternative 2, where modified area control harvest 
would be approximately 4 MM bd. ft, and 
Alternative 9, where harvest would be 
approximately 6 MM bd. ft. In actual practices, the 
volume generated would probably be 
concentrated during the last half of the decade, 
rather than occurring as a constant annual flow. 
This is caused by the necessity to complete 
detailed habitat and visual management plans on a 
number of these areas prior to scheduling timber 
harvests. 

Forest land acres and age class distribution were 
determined individually for the allocations to 
benefit each resource. A listing of lands proposed 
for modified area control was developed as 
follows: 



Resource Allocation 

Mid-age and 
Old Growth 
Riparian 
VRM II 

TOTAL 



Comi 


mercial Forest Land 
Acres 1 


Alt. 2 


Alts. 3, 
4& 7 


Alt. 9 


2,772 

18,332 

3,682 


32,882 

16,519 

2,646 


33,210 



2,658 



24,786 52,047 



35,868 



' Overlaps between resource allocations were eliminated. 



Mid-age and old-growth is located in loosely 
arranged corridors. Ties with corridors in 
adjoining BLM districts are incorporated. These 
components also include functioning old growth 
systems distributed by seed zone and elevation in 
order to safeguard long term timber productivity 
(see Serai Stage Distribution Concept, Appendix 
A). 



That portion of the allocated mid-age and old 
growth which exists as 80-acre blocks would be 
managed to maintain, as a minimum, 70 percent of 
these blocks in the 120+ age class. Normally, 
management would be to harvest the entire 
selected block within a decade to create an even- 
age stand, thereby attaining desired wildlife values 
in the future. 

Osprey and heron habitat would be managed with 
seasonal harvest limitations to avoid disturbance 
of nesting pairs. When osprey and heron habitat 
overlaps visual protection areas, timber harvest 
would be managed in conjunction with VRM plans 
to maintain visual quality. Harvest in VRM II zones 
would be conducted according to the sequential 
settings delineated in the visual resource 
management plans. All visual plans are scheduled 
for completion by 1989. 

Modified Area Control on Riparian 
Areas 

For Alternatives 2, 3, 4 and 7 approximately 
18,300 acres of riparian areas along third order 
and greater streams would be managed in 
vegetative buffers averaging 200 feet wide. This 
includes the actual riparian habitat (10,650 acres) 
shown in Chapter 2 plus additional transitional 
vegetation (7,650 acres). These areas would be 
managed to provide riparian values, including 
habitat structure important to cavity dwellers and 
other species, to maintain shade and woody 
structure important to fish habitat and to protect 
stream bank stability for water quality and 
temperature control. 

Prior to timber management activities in these 
areas, site specific interdisciplinary plans would 
be completed to delineate riparian values as well 
as appropriate harvest levels and project design 
features. 

In riparian areas, clearcuts would be permitted for 
road crossings, yarding corridors and harvest of 
small isolated parcels. This would permit access 
to the majority of the district land base, while 
minimizing impacts to a small portion of the 
riparian area. According to the sample 5-year 
timber sale plan, approximately 12 acres of 
riparian vegetation would be clearcut each year. 

In addition, the sample 5-year timber sale plan 
includes approximately 96 acres that would be 
partial cut each year. In partial cut areas, 
silvicultural systems ranging from individual tree 
selection to group selection or shelterwood would 
be used. 

The remaining areas of riparian vegetation are not 
planned for entry during the first decade. 

Management practices which would be applied to 
riparian areas (including streamside buffers) 
include directional falling of timber away from 



170 



streams, no machinery operation in streams 
(except for road construction, e.g., bridges and 
culverts) and full suspension yarding across 
riparian management areas. No burning would be 
conducted in the riparian management areas. 

As information and greater understanding 
regarding the management of these areas are 
gained throughout the decade, necessary 
revisions would be incorporated into the next 
planning cycle. 

Allowable Cut Computation 
Forest Simulation Model 

A computerized forest simulation model 
(SIMIX) is used to determine the highest 
sustainable allowable cut for each alternative. 
SIMIX calculates the allowable cut associated with 
the stated forest management plan. It can 
maximize an even-flow level of cut for some 
specific management regime, or a series of cut 
levels may be specified for as many as the first 10 
decades followed by an even-flow level for the 
remainder of the projected period (40 decades). 
This lengthy projection period is not an attempt at 
a 400-year plan. It is used only to assure that the 
condition of no planned reduction in allowable cut 
can be met. 

The clearcut option of SIMIX was utilized since 
clearcut is the predominant harvest method in all 
alternatives. For accuracy in measuring lumber 
and plywood production, the allowable cut is 
computed and projected into the future on the 
basis of cubic feet. 

SIMIX computes the harvest level based on 
present inventory and projected growth resulting 
from the application of certain management 
practices (mortality salvage, precommercial and 
commercial thinning, commercial thinning only, 
forest genetics and final harvest cuts). Another 
treatment, fertilization, is included in conjunction 
with one or more of the above treatments. SIMIX 
must be told what treatments, when and the 
number of acres, to be treated. No rotation age is 
set; instead, a minimum cutting age constraint is 
specified. SIMIX is not designed to handle 
economic values or costs, and it does not seek out 
alternative schedules or strategies. 

The model, designed for forests under an even- 
aged system of management, produces output 
data by decades for each age and treatment class 
and summarizes them numerically and 
graphically. These data include level of growing 
stock, annual growth, acreage by silvicultural 
practices and volume by harvesting practice. 
Consequently, it permits alternative plans to be 
evaluated on the basis of their respective 
production levels and fiscal requirements and 
serves as a basis for programming personnel and 
funds for the alternative selected. In effect, a 



management plan is developed that schedules the 
production from commercial thinning, mortality 
salvage and final harvest operations and also the 
acreages for such treatments as reforestation and 
precommercial thinning. The model is geared to 
the proposed policies but is flexible to the extent 
that other regulatory policies can be applied in its 
use. 

The Allowable Cut Effect (ACE) 

A forest that is composed primarily of 
old-growth timber and recently cut-over stands 
exhibits a relatively low average annual growth. 
This results from slow or negative growth of the 
old stands and the fact that growth is not 
measurable (in end-product terms) in the young 
stands until they reach 20 or 30 years of age. Such 
a forest is in transition from an unmanaged to a 
managed or regulated state. In the classical sense, 
the regulated state is achieved when average 
annual harvest and growth are in equilibrium. At 
this point, maximum yield on a sustainable basis is 
reached. To compute an allowable cut on a forest 
in the transition state using this criteria would be 
extremely conservative and greatly lengthen the 
time until the regulated state was achieved. The 
BLM uses an alternative approach which is to 
project growth into the future based upon 
assumptions about management levels and to 
utilize excess harvest age timber to bridge the 
time gap until the ultimate growth level is 
achieved. This process of taking credit now for 
future growth increases expected to result from 
management has been termed the "Allowable Cut 
Effect" (ACE). 

Figure C-1 illustrates this process in the context of 
conditions found in the SYUs, before land use 
allocations were made to other resource activities. 

This forest is in the early to middle transition stage 
and, as the recent inventory found, has a relatively 
low average annual growth rate. An initial 
computation was made that assumed no intensive 
management practices were performed. Under 
this scheme, stands were projected to grow in a 
fashion similar to normal unmanaged forests. The 
lower growth curve in Figure C-1 shows the 
average annual growth path projected from these 
assumptions. When tested on the allowable cut 
model, it was determined that sufficient harvest 
age timber was available to bridge the gap until a 
regulated state was achieved. 

Next, a high level of management was assumed. 
Practices (see Chapter 1, Forest Management 
Treatments and Design Elements) such as genetic 
improvement, precommercial and commercial 
thinning, fertilization and mortality salvage were 
used in projecting yield functions. The basis for 
most of these projections was the DFIT model. 
The higher growth curve in Figure C-1 shows the 
average annual growth path resulting from the 
intensive management assumptions. When tested 



171 



on the allowable cut model, it was determined that 
there was only enough harvest age timber 
available to take credit for a portion of the 
expected future growth increases. For full ACE 
credit to apply, there must be enough harvestable 
timber to bridge the previously mentioned time 
gap. Since this was not the case in the Roseburg 
SYUs, the allowable cut effect applied was limited 
to about 53 percent of the projected potential 
allowable cut effect. To set a cut level higher than 
the "actual" would cause a drop in future cut 
levels, a violation of Bureau policy. The foregoing 
narrative is supplemented by Figure C-2 which 
portrays both data source and information flow 
sequence for the allowable cut determination 
process. 



FIGURE C-l 
ALLOWABLE CUT EFFECT 









ALLOWABLE 








CUT 






POTENTIAL HARVEST 


WITH INTENSIVE MANAGEMENT 


EFFECT 


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172 



Figure C-2 



Bureau Planning System 
All Resource Data 



Allowable Cut Planning System 
Forestry Data 



Policy, Guidance, 
Socio-economic Data 



Resource Analysis 
Existing Situation 

• Present forest condition 



Summary Data 



Opportunities 

Initial decade treated acres by intensive management practice 
Ultimate acreage to undergo Intensive management 
Yields for each intensive management practice 



1 



Management Framework Plans 

• Select forest management practices which meet the test 
of environmental and economic feasibility 




Forest Management Policy 
minimum harvest age 



District Inputs 



i— Forest Reinventory 



Timber Production 
Capability Classification 



Regeneration Lag 



Emperic and Non-treated 
Yield Curves (DFIT) 



Final Harvest Acres 
by Cutting Practice 



Young Growth Management Committee Report 
Feasible and unfeasible intensive management practices 



Operations Inventory 
Forest Stand Development Opportunities 



Land Use Allocation - Acres 
Decisions resolving conflicting opportunities 

• Based on tests of various multiple use constraints 



Environmental Impact Statement 

Draft and final documents analyze impacts of proposed 
action and other alternatives 



Decision 
Allowable cut declared, management framework plan 
implemented 



Simix Model 

Inputs: 

• Acreage and age class distribution in allowable cut land base' 

• Minimum harvest age' 

• Acreages to be treated during initial decade by intensive management' 

• Ultimate acreage to undergo intensive management' 

• Empirical and non-treated yields' 

• Yields for each intensive management practice' 

• Regeneration lag 

• Acreage removed from the timber production base by decade due to roading 

• Acreage constrained because of multiple use consideration 

• Acreage foregone because of multiple use consideration 

Outputs: 

Decadal printout covering 40 decades contains 

• Even flow volume 

• Age class distribution 

• Acreages for PCT 

• Acreages and volumes for commercial thinning, morlality salvage and final 
harvest 

• Growth and standing volumes 

'Primary determinants of the degree of allowable cut effect 



Appendix D Wildlife 



173 



Conifer Habitat 



Other Habitat 



Key 

Resident Habitat 

P=Permanent U=Uses 

S=Summer 0=Optimum 

W=Winter 
M=Migratory 

Relative Abundance 

A=Abundant 
C=Common 
U=Uncommon 
R=Rare 

Mammals 

Virginia Opossum (Didelphis virginiana) 

Vagrant Shrew (Sorex vagrans) 

Dusky Shrew (Sorex obscurus) 

Pacific Shrew (Sorex pacificus) 

Virginia Opossum (Didelphis virginiana) 

Vagrant Shrew 

Water Shrew (Sorex palustris) 

Pacific Water Shrew (Sorex bendirii) 

Trowbridge's Shrew (Sorex trowbridgii) 

Shrew-mole (Neurotrichus gibbsii) 

Townsend's Mole (Scapanus townsendii) 

Coast Mole (Scapanus orarius) 

Little Brown Myotis (Myotis lucifugus) 

Yuma Myotis (Myotis yumanensis) 

Long-eared Myotis (Myotis evotis) 

Fringed Myotis (Myotis thysanodes) 

Long-legged Myotis (Myotis volans) 

California Myotis (Myotis californicus) 

Silver-haired Bat (Lasionycteris noctivagans) 

Big Brown Bat (Eptesicus fuscus) 

Hoary Bat (Lasiurus cinereus) 

Townsend's Big-eared Bat (Plecotus townsendii) 

Pallid Bat (Antrozous pallidus) 

Brazilian Free-Tailed Bat (Tadarida brasiliensis) 

Pika (Ochotona princeps) 

Brush Rabbit (Sylvilagus bachmani) 

Snowshoe Hare (Lepus americanus) 

Black-tailed Jackrabbit (Lepus californicus) 

Mountain Beaver (Aplodentia rufa) 

Townsend's Chipmunk (Eutamias townsendii) 

California Ground Squirrel (Spermophilus beecheyi) 

Western Gray Squirrel (Sciurus griseus) 

Douglas' Squirrel (Tamiasciurus douglasii) 

Northern Flying Squirrel (Glaucomys sabrinus) 

Botta's Pocket Gopher (Thomomys bottae) 

Western Pocket Gopher (Thomomys mazama) 

Beaver (Castor canadensis) 

Deer Mouse (Peromyscus maniculatus) 

Dusky-footed Woodrat (Neotoma fuscipes) 

Bushy-tailed Woodrat (Neotoma cinerea) 

Western Red-backed Vole (Clethrionomys occidentalis) 

White-footed Vole (Phenacomys albipes) 

Red Tree Vole (Phenacomys longicaudus) 

California Vole (Microtus californicus) 

Townsend's Vole (Microtus townsendii) 

Long-tailed Vole (Microtus longicaudus) 

Creeping Vole (Microtus oregoni) 

Muskrat (Ondatra zibethicus) 

Norway Rat (Rattus norvegicus) 

House Mouse (Mus musculus) 

Pacific Jumping Mouse (Zapus trinotatus) 

Porcupine (Erethizon dorsatum) 

Nutria (Myocaster coypus) 

Coyote (Canis latrans) 

Red Fox (Vulpes vulpes) 

Gray Fox (Urocyon cinereoargenteus) 



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174 



Appendix D Wildlife (continued) 



Conifer Habitat 



Key 

Resident Habitat 

P=Permanent U=Uses 

S=Summer 0=Optimum 

W^Winter 
M-Migratory 

Relative Abundance 

A=Abundant 
OCommon 
U^Uncommon 
R=Rare 



Black Bear (Ursus americanus) 

Ringtail (Bassariscus astutus) 

Raccoon (Procyon lotor) 

Marten (Martes americana) 

Fisher (Martes pennanti) 

Ermine (Mustela erminea) 

Long-tailed Weasel (Mustela frenata) 

Mink (Mustela vison) 

Western Spotted Skunk (Spilogale gracilis) 

Striped Skunk (Mephitis mephitis) 

River Otter (Lutra canadensis) 

Mountain Lion (Felis concolor) 

Bobcat (Felis rufus) 

Roosevelt Elk (Cervus elaphus rooseveltii) 

Columbian Black-tailed Deer 

Odocoileus hemionus columbianus) 
Columbian White-tailed Deer 

(Odocoileus Virginians leucurus) 

Birds 

Common Loon (Gavia immer) 

Eared Grebe (Podiceps nigricollis) 

Western Grebe (Aechmophorus occidentalis) 

Pied-billed Grebe (Podilymbus podiceps) 

Double-crested Cormorant (Phalacrocorax auritus) 

Great Blue Heron (Ardea herodias) 

Green Heron (Butorides striatus) 

Great Egret (Casmerodius albus) 

Black-crowned Night Heron (Nycticorax nycticorax) 

American Bittern (Botarus lentiginosus) 

Whistling Swan (Olor columbianus) 

Canada Goose (Branta canadensis) 

White-fronted Goose (Anser albifrons) 

Snow Goose (Chen caerulescens) 

Mallard (Anas platyrhynchos) 

Gadwall (Anas strepera) 

Pintail (Anas acuta) 

Green-winged Teal (Anas crecca) 

Blue-winged Teal (Anas discors) 

Cinnamon Teal (Anas cyanoptera) 

American Wigeon (Anas americana) 

Northern Shoveler (Anis clypeata) 

Wood Duck (Aix sponsa) 

Redhead (Aythya americana) 

Ring-necked Duck (Aythya collaris) 

Canvasback (Aythya valisineria) 

Greater Scaup (Aythya marila) 

Lesser Scaup(Aythya affinis) 

Common Goldeneye (Bucephala clangula) 

Bufflehead (Bucephala albeola) 

Ruddy Duck (Oxyura jamaicensis) 

Hooded Merganser (Lophodytes cucullatus) 



Other Habitat 



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Appendix D Wildlife (continued) 



175 



Conifer Habitat 



Other Habitat 



Key 

Resident Habitat 

P=Permanent U^Uses 

S=Summer OOptimum 

W=Winter 
M=Migratory 

Relative Abundance 

A-- Abundant 
OCommon 
U=Uncommon 
R=Rare 



Common Merganser (Mergus Merganser) 
Red-breasted Merganser (Mergus serrator) 
Turkey Vulture (Cathartes aura) 
Northern Goshawk (Accipiter gentilis) 
Sharp-shinned Hawk (Accipiter striatus) 
Cooper's Hawk (Accipiter cooperi) 
Red-tailed Hawk (Buteo jamaicensis) 
Rough-legged Hawk (Buteo lagopus) 
Golden Eagle (Aquila chrysaetos) 
Bald Eagle (Haliaeetus leucocephalus) 
Northern Harrier (Circus cyaneus) 
Osprey (Pandion haliaetus) 
Prairie Falcon (Falco mexicanus) 
Merlin (Falco columbarius) 
American Kestrel (Falco sparverius) 

Blue Grouse (Dendragapus obscurus) 

Ruffed Grouse (Bonasa umbellus) 

California Quail (Lophortyx californicus) 

Mountain Quail (Oreortyx pictus) 

Ring-necked Pheasant (Phasianus colchicus) 

Virginia Rail (Rallus limicola) 

Sora (Porzana Carolina) 

American Coot (Fulica americana) 

Semi-palmated Plover (Calidris pusilla) 

Killdeer (Charadrius vociferus) 

Common Snipe (Capella gallinago) 

Spotted Sandpiper (Actitis macularia) 

Solitary Sandpiper (Tringa solitaria) 

Greater Yellowlegs (Tringa melanoleucus) 

Lesser Yellowlegs (Tringa flavipes) 

Least Sandpiper (Calidris minutilla) 

Long-billed Dowitcher (Limnodromus scolopaceus) 

Dunlin (Calidris alpina) 

Western Sandpiper (Calidris mauri) 

Short-billed Dowitcher (Limnodromus griseus) 

Northern Phalarope (Lobipes lobatus) 

Glaucous-winged Gull (Larus glaucescens) 

Western Gull (Larus occidentalis) 

Herring Gull (Larus argentatus) 

California Gull (Larus californicus) 

Ring-billed Gull (Larus delawarensis) 

Band-tailed Pigeon (Columba fasciata) 

Rock Dove (Columba livia) 

Mourning Dove (Zengida macroura) 
Barn Owl (Tyto alba) 
Screech Owl (Otus asio) 
Great Horned Owl (Bubo virginianus) 
Snowy Owl (Nyctea scandiaca) 
Pygmy Owl (Glaucidium gnoma) 
Northern Spotted Owl (Strix occidentalis) 
Short-eared Owl (Asio flammeus) 
Saw-whet Owl (Aegolius acadicus) 



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176 



Appendix D Wildlife (continued) 



Conifer Habitat 



Other Habitat 



Key 

Resident Habitat 

P=Permanent LNUses 

S=Summer 0=Optimum 

W=Winter 
M=Migratory 

Relative Abundance 

A-Abundant 
C=Common 
U-Uncommon 
R=Rare 



Common Nighthawk (Chordeiles minor) 
Vaux's Swift (Chaetura vauxi) 
Anna's Hummingbird (Calypte anna) 
Rufous Hummingbird (Selasphorus rufus) 
Belted Kingfisher (Megaceryle alcyon) 
Common Flicker (Colaptes auratus) 
Pileated Woodpecker (Dryocopus pileatus) 
Acorn Woodpecker (Melanerpes formicivorus) 
Lewis Woodpecker (Melanerpes lewis) 
Yellow-bellied Sapsucker (Sphyrapicus varius) 
Hairy Woodpecker (Picoides villosus) 
Downy Woodpecker (Picoides pubescens) 
Western Kingbird (Tyrannus verticalis) 
Ash-throated Flycatcher (Myiarchus cinerascens) 
Willow Flycatcher (Empidonax traillii) 
Hammond's Flycatcher (Empidonax hammondii) 
Dusky Flycatcher (Empidonax oberholseri) 
Western Flycatcher (Empidonax difficilis) 
Western Wood Pewee (Contopus sordidulus) 
Olive-sided Flycatcher (Nuttallornis borealis) 
Violet-green Swallow (Tachycineta thalassina) 
Tree Swallow (Iridoprocne bicolor) 
Bank Swallow (Riparia riparia) 
Rough-winged Swallow (Stelgidopteryx ruficollis) 
Barn Swallow (Hirundo rustica) 
Cliff Swallow (Petrochelidon pyrrhonota) 
Purple Martin (Progne subis) 

Gray Jay (Perisoreus canadensis) 
Steller's Jay (Cyanocitta stelleri) 
Scrub Jay (Aphelocoma coerulescens) 
Northern Raven (Corvus corax) 
American Crow (Corvus brachyrhynchos) 
Black-capped Chickadee (Parus atricapillus) 
Mountain Chickadee (Parus gambeli) 
Chestnut-backed Chickadee (Parus rufescens) 
Bushtit (Psaltriparus minimus) 
White-breasted Nuthatch (Sitta carolinensis) 
Red-breasted Nuthatch (Sitta canadensis) 
Pygmy Nuthatch (Sitla pygmea) 
Brown Creeper (Certhia familaris) 
Wrentit (Chamaea fasciata) 
Dipper (Cinclus mexicanus) 
House Wren (Troglodytes aedon) 
Winter Wren (Troglodytes trogladytes) 
Bewick's Wren (Thryomanes bewickii) 
Long-billed Marsh Wren (Cistothorus palustris) 
American Robin (Turdus migratorius) 
Varied Thrush (Ixoreus naevius) 
Hermit Thrush (Catharus guttata) 
Swainson's Thrush (Catharus ustulata) 
Western Bluebird (Sialia mexicana) 
Townsend's Solitaire (Myadestes townsendi) 
Golden-crowned Kinglet (Regulus satrapa) 



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Appendix D Wildlife (continued) 



177 



Conifer Habitat 



Other Habitat 



Key 

Resident Habitat 

P^Permanent U=Uses 

S=Summer 0=Optimum 

W=Winter 
M=Migratory 

Relative Abundance 

A-Abundant 
OCommon 
U=Uncommon 
R=Rare 



Ruby-crowned Kinglet (Regulus calendula) 
Water Pipit (Anthus spinoletta) 
Bohemian Waxwing (Bombycilla garrulus) 
Cedar Waxwing (Bombycilla cedrorum) 
Northern Shrike (Lanius excubitor) 
Starling (Sturnus vulgaris) 
Hutton's Vireo (Vireo huttoni) 
Solitary Vireo (Vireo solitarius) 
Warbling Vireo (Vireo gilvus) 

Orange-crowned Warbler (Vermivora celata) 
Nashville Warbler (Vermivora ruficapilla) 
Yellow Warbler (Dendroica petechia) 
Yellow-rumped Warbler (Dendroica coronata) 
Black-throated Gray Warbler (Dendroica nigrescens) 
Townsend's Warbler (Dendroica townsendi) 
Hermit Warbler (Dendroica occidentalis) 
MacGillivray's Warbler (Oporornis tolmiei) 
Yellowthroat (Geothlypis trichas) 
Yellow-breasted Chat (Icteria virens) 
Wilson's Warbler (Wilsonia pusilla) 
House Sparrow (Passer domesticus) 
Western Meadowlark (Sturnella neglecta) 
Yellow-headed Blackbird 

(Xanthocephalus xanthocephalus) 
Red-winged Blackbird (Agelaius phoeniceus) 
Northern Oriole (Icterus galbula) 
Brewer's Blackbird (Euphagus cyanocephalus) 
Brown-headed Cowbird (Molothrus ater) 
Western Tanager (Piranga ludoviciana) 
Black-headed Grosbeak 

(Pheucticus melanocephalus) 
Lazuli Bunting (Passerina amoena) 
Evening Grosbeak (Hesperiphona vespertina) 
Purple Finch (Carpodacus purpureus) 
House Finch (Carpodacus mexicanus) 
Pine Siskin(Carduelis pinus) 
American Goldfinch (Carduelis tristis) 
Lesser Goldfinch (Carduelis psaltria) 
Red Crossbill (Loxia curvirostra) 
Rufous-sided Towhee (Pipilo erythrophthalmus) 
Savannah Sparrow (Passerculus sandwichensis) 
Vesper Sparrow (Pooecetes gramineus) 
Dark-eyed Junco (Junco hyemalis) 
Chipping Sparrow (Spizella passerina) 
White-crowned Sparrow (Zonotrichia leucophrys) 
Golden-crowned Sparrow (Zonetrichia atricapilla) 
Fox Sparrow (Passerella iliaca) 
Lincoln's Sparrow (Melospiza lincolnii) 
Song Sparrow (Melospiza melodia) 



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178 



Appendix D Wildlife (continued) 



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Other Habitat 



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W=Winter 
M-Migratory 

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Reptiles 

Western Pond Turtle (Clemmys marmorata) 
Western Fence Lizard (Sceloporus occidentalis) 
Western Skink (Eumeces skiltonianus) 
Southern Alligator Lizard 

(Gerrhonotus multicarinatus) 
Northern Alligator Lizard (Gerrhonotus coeruleus) 
Rubber Boa (Charina bottae) 
Ringneck Snake (Diadophis punctatus) 
Sharp-tailed Snake (Contia tenuis) 
Western Yellow-bellied Racer (Coluber constrictor) 
Pacific Gopher Snake (Pituophis melanoleucus) 
Common Kingsnake (Lampropeltis getulus) 
California Mountain Kingsnake (Lampropeltis zonata) P 
Common Garter Snake (Thamnophis sirtalis) 
Western Terrestrial Garter Snake 

(Thamnophis elegans) 
Western Aquatic Garter Snake (Thamnophis couchi) 
Northwestern Garter Snake (Thamnophis ordinoides) 
Western Rattlesnake (Crotalus molossus) 



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Amphibians 

Northwestern Salamander (Ambystoma gracile) 
Long-toed Salamander (Ambystoma macrodactylum) 
Pacific Giant Salamander (Dicamptodon ensatus) 
Olympic Salamander (Rhyacotriton olympicus) 
Rough-skinned Newt (Taricha granulosa) 
Dunn's Salamander (Plethodon dunni) 
Western Red-backed Salamander 

(Plethodon vehiculum) 
Oregon Salamander (Ensatina eschscholtzi) 
Clouded Salamander (Aneides ferreus) 
Tailed Frog (Ascaphus truei) 
Western Toad (Bufo boreas) 
Pacific Tree Frog (Hyla regilla) 
Red-legged Frog (Rana aurora) 
Yellow-legged Frog (Rana boylei) 
Bullfrog (Rana catesbeiana) 



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Appendix E 



179 





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189 



Glossary of Terms 



Absorb - To be held within the structure of a 
substance. 

Acre-foot - The volume of water that will cover 
one acre to a depth of one foot. 

Adsorb - To be held on the surface of a substance. 

Allowable Cut - The amount of forest products 
that may be harvested annually or periodically 
from a specified area over a stated period in 
accordance with the objectives of management. 

Allowable Cut Effect (ACE) - The immediate 
increase in today's allowable cut which is justified 
by expected future increases in yields due to 
present or proposed management treatments. 

Allowable Cut Determination Process - A process 
which deals with the steps involved in the 
development and evaluation of alternative levels of 
timber production for the purpose of establishing 
an allowable cut. 

Ambient - Surrounding, on all sides; for air, refers 
to any unconfined portion of the atmosphere. 

Anadromous Fish - Fish which migrate from the 
sea to breed in fresh water. Their offspring return 
to the sea. 

Aquifer - A geologic formation or structure that 
transmits water in sufficient quantity to supply the 



needs for a water development; usually saturated 
sands, gravel, fractures, and cavernous and 
vesicular rock. The term water-bearing is 
sometimes used synonymously with aquifer when 
a stratum furnishes water for a specific use. 

Archeological Resources - All evidences of past 
human occupations other than historical 
documents, which can be used to reconstruct the 
lifeways of past peoples. These include sites, 
artifacts, environmental data and all other relevant 
information. 

Area of Critical Environmental Concern (ACEC) - 

An area within the public lands where special 
management attention is required (when such 
areas are developed or used, or where no 
development is required) to protect and prevent 
irreparable damage to important historic, cultural, 
or scenic values, fish and wildlife resources or 
other natural systems or processes, or to protect 
life and safety from natural hazards (FLPMA Sec. 
103(a)). 

Aspect - The direction a slope faces. 

Average Employment - The sum of number of 
employees, reported monthly, divided by twelve; 
because employment is reported for all employees 
working during any one month, it is a modest 
over-estimate of full-time equivalent employment. 



190 

Background - That portion of an area being 
viewed beyond the foreground-middleground (3 to 
5) miles to a maximum of about 15 miles from a 
travel route, use area, or other observer position. 

Background Levels - Amounts of pollutants 
present from natural sources and from human 
disturbances which have reached equilibrium. 

Basal Area - The area of the cross-section of a 
tree stem near its base, generally at breast height 
and inclusive of bark. It is usually expressed as 
square feet per acre. 

Bedload - The sediment that moves by sliding, 
rolling or bounding, on or very near, the 
streambed. 

Biome - The largest land community unit (plant 
and animal) which is convenient to recognize. 

Board Foot - A unit of solid wood, 1-foot square 
and 1-inch thick. 

British Thermal Unit (Btu) - A unit of heat equal to 
252 calories; quantity of heat needed to raise the 
temperature of one pound of water from 62 F. to 
63 F. 

Broadcast Burning - Intentional burning in which 
fire is intended to spread over all of a specific 
area. It may or may not qualify as prescribed 
burning. 

Bucking - Cutting trees into log lengths. 

Buffer Strip - A protective area adjacent to an area 
requiring special attention or protection. 

Bureau Planning System - A process used in the 
BLM to establish land use allocations, constraints, 
and objectives for various categories of public 
land use. 

Characteristic Landscape - The established 
landscape within a physiographic province. The 
term does not necessarily mean "naturalistic 
character." It could refer to farm lands, timber 
lands or other landscapes which exhibit both 
physiographic and land use similarities. 

Clearcutting - A method of timber harvesting in 
which all trees, merchantable or unmerchantable, 
are cut from an area. 

Commercial Forest Land - Forest land that is now 
producing or is capable of producing at least 20 
cubic feet per acre per year of commercial 
coniferous tree species. 

Commercial Thinning - Partial cuttings made in 
merchantable stands (40-70 years old) in order to 
stimulate the growth of remaining trees and 
increase total yield from the stand. 

Community Income Effect - The sum of direct and 
indirect personal income generated by a change, 



e.g., timber harvest. Indirect personal income 
results from economic activity stimulated in other 
local enterprises by purchase of goods and 
services, primarily of a support nature. 

Constrained Timber Production Base - Base 
acreage managed for timber production at a lesser 
intensity in consideration for other resource 
management objectives, e.g., minimum harvest 
ages of 60 to 350 years for wildlife habitat (see 
Intensive Timber Production Base). 

Contrast - The effect of a striking difference in the 
form, line, color or texture of the landscape 
features within the area being viewed. 

Contrast Rating System - A method of 
determining the extent of visual impact for an 
existing or proposed activity that will modify any 
landscape feature (land and water form, 
vegetation and structures). 

Coos Bay Wagon Road (CBWR) Lands - Public 
lands granted to the Southern Oregon Company 
and subsequently reconveyed to the United 
States. 

Critical Habitat - That habitat considered by the 
Secretary of the Interior to be necessary to the 
normal needs or survival and recovery of listed 
Threatened or Endangered Species. It may also 
include habitat not currently occupied into which 
a listed species could expand. 

Cull - A tree or log which is rejected because it 
does not meet certain specifications. 

Cultural Resources - Those fragile and 
nonrenewable remains of human activity, 
occupation, or endeavor, reflected in districts, 
sites, structures, buildings, objects, artifacts, 
ruins, works of art, architecture, and natural 
features, that were of importance in human events. 
These resources consist of (1) physical remains, 
(2) areas where significant human events 
occurred—even though evidence of the event no 
longer remains, and (3) the environment 
immediately surrounding the actual resource. 
Cultural resources, including both prehistoric and 
historic remains, represent a part of the 
continuum of events from the earliest evidences of 
man to the present day. 

Debris Avalanche - Fast moving failures of 
shallow, generally cohesionless soils on steep 
slopes over an impermeable failure surface. 

Debris Torrent - A very fluid mass of soil, rock and 
vegetative debris that moves rapidly down steep, 
narrow stream channels. 

Discharge - Rate of flow of a fluid, the volume of 
fluid passing a point per unit of time, commonly 
expressed as cubic feet per second (cfs), million 
gallons per day, gallons per minute, or cubic 
meters per second. 



191 



Distance Zone - The area that can be seen as 
foreground-middleground, background, or 
seldom-seen. 

Ecosystem - An ecological unit consisting of both 
living and nonliving components which interact to 
produce a natural, stable system. 

Environmental Assessment (EA) - A systematic 
environmental analysis of site-specific BLM 
activities used to determine whether such 
activities have a significant effect on the quality of 
the human environment and whether a formal 
environmental impact statement is required. 

Environmental Impact Statement (EIS) - A formal 
document to be filed with the Environmental 
Protection Agency that considers significant 
environmental impacts expected from 
implementation of a major federal action. 

Erosion (soil) - Removal of soil from its place of 
origin to a point of deposition other than a stream 
channel. 

Even Flow - Maintaining a relatively constant 
undiminishing supply of timber from year to year 
for the planning cycle. 

Fauna - All the animals in a given area. 

Final Harvest Cut - Constitutes removal of a 
mature stand, either through clearcutting, the final 
stage of a shelterwood regime, or overstory 
removal. 

Flora - All the plants in a given area. 

Forbs - Herbaceous plants; most often used 
pertaining to herbaceous plants eaten by wildlife. 

Foreground-middleground - The area visible from 
a travel route, use area, or other observer position 
to a distance not exceeding five miles. The outer 
boundary of this zone is defined as the point 
where the texture and form of individual plants are 
no longer apparent in the landscape. Vegetation is 
apparent only in patterns or outline. 

Forest Canopy - The more or less continuous 
cover of branches and foliage formed collectively 
by the crowns of adjacent trees and other woody 
growth. 

Forest Land - Land that is now, or is capable of 
becoming, at least 10 percent stocked with forest 
trees and that has not been developed for 
nontimber use. 

Forest Management Program - Includes timber 
activity plan and all forest resource related 
program activity plans. 

Forest Type Island - An aggregation of trees 
occupying a specific area and sufficiently uniform 
in composition, age, arrangement and condition to 



be distinguishable from vegetation on adjoining 
areas. 

Groundwater - Subsurface water in the zone of 
saturation. 

Growing Stock - The amount of standing, green 
timber retained to produce forest products; also 
known as forest capital. 

Habitat - The environment in which an organism 
occurs. 

High-lead Logging - A cable yarding system in 
which lead blocks are hung on a spar or tower to 
provide lift to the front end of logs giving partial 
suspension. 

Historic Resources - All evidences of human 
activity that date from historic (i.e., recorded 
history) periods. These resources include 
documentary data (i.e., written records, archival 
material, photographs, maps, etc.), sites, artifacts, 
environmental data, and all other relevant 
information. Also included are locations where 
documented historical events took place, even 
though no physical evidence of the events remain 
other than the setting. Historic resources are 
cultural resources and may be considered 
archeological resources when archeological work 
is involved in their identification and 
interpretation. 

Igneous Rock - Rock formed from the cooling and 
solidification of molten rock. 

Infiltration (soil) - Downward entry of water into 
the soil. 

Intensive Forest Management Lands - All 

commercial forest land that is part of the timber 
production base for allowable cut calculation in 
the Douglas and South Umpqua Sustained Yield 
Units. 

Intensive Timber Production Base - Base acreage 
intensively managed for timber production using a 
50-year minimum harvest age in the allowable cut 
computation. 

Intermediate Cuttings - Any removal of 
merchantable trees from a stand prior to the final 
harvest cutting, i.e., commercial thinning, 
sanitation/salvage, or shelterwood regeneration 
cuttings. 

Landing - Any place on or adjacent to the logging 
site where logs are assembled for further 
transport. 

Landscape Features - The land and water form, 
vegetation, and structures which compose the 
characteristic landscape. 



192 



Leach - Usually refers to the movement of 
chemicals through soil by water; may also refer to 
movement of herbicides out of leaves, stems or 
roots into the air or soil. 

Log Flows - Destinations of harvested timber by 
origin. Origins used herein are management units 
and counties or county groupings; destinations 
are communities, counties or groupings of 
counties within which the primary processing of 
timber takes place. 

Lumber and Wood Products, except Furniture - 

Defined by the Office of Management and Budget 
and the Standard Industrial Classification Manual 
as Major Group #24, which includes logging 
contractors engaged in cutting timber and 
pulpwoods; merchant sawmills, lath mills, shingle 
mills, planing mills, plywood mills, and veneer 
mills engaged in producing lumber and wood 
basic materials; and establishments engaged in 
manufacturing finished articles made entirely or 
mainly of wood or wood substitutes. Certain types 
of establishments producing wood products are 
classified elsewhere, e.g., furniture and office and 
store fixtures are classified in Major Group #25. 

Management Framework Plan (MFP) - Land use 
plan for public lands which provides a set of goals, 
objectives, and constraints for a specific planning 
area to guide the development of detailed plans 
for the management of each resource. 

Mass Failure - See Mass Movement. 

Mass Movement - Downslope movement of soil 
and rock caused by gravity; may be slow (creep) 
or rapid (landslide, debris avalanche). 

Metamorphic Rock - Rock formed from 
preexisting rocks but changed by heat and/or 
pressure to rock with new physical, chemical and 
mineralogical properties. 

Microclimate - The climatic condition of a small 
area modified from the general climatic conditions 
by local differences in elevation or exposure. 

Minimum Harvest Age - The lowest age of a stand 
to be scheduled for final harvest. 

Mixing Height - The height above the ground 
through which vertical mixing of air is relatively 
vigorous. 

Mortality Salvage - See sanitation/salvage cutting. 

Multiple Use - Management of the public lands 
and their various resource values so that they are 
utilized in the combination that will best meet the 
present and future needs of the American people. 

National Natural Landmark - Areas designated by 
the Secretary of Interior which contain 
representative examples of the nation's natural 
history, including terrestrial communities, aquatic 



communities, landforms, geological features or 
habitats of native plant and animal species, 
possessing national significance in illustrating or 
interpreting the nation's natural heritage. 

National Register of Historic Places - The official 
list, established by the Historic Preservation Act of 
1966, of the Nation's cultural resources worthy of 
preservation. The Register lists archeological, 
historic, and architectural properties (i.e., districts, 
sites, buildings, structures, and objects) 
nominated for their local, State, or national 
significance by State and/or Federal agencies and 
approved by the National Register staff. The 
Register is maintained by the National Park 
Service. 

Natural Levels - Amount of pollutants present 
from natural sources without human disturbances 
which have reached equilibrium. 

Non-commercial Forest Land - Land which is not 
capable of yielding at least 20 cubic feet of wood 
per acre per year from commercial species, or 
land which is capable of producing only non- 
commercial tree species. 

Non-degradation Policy - Use of the highest and 
best practicable treatment and/or control of 
wastes, activities and flows to maintain water 
quality at the highest possible levels. 

Non-forest Land - Land that has been developed 
for non-timber uses or land that is incapable of 
being 10 percent stocked with forest trees. 

Non-point Source Pollution - Pollution caused by 
the introduction of materials from diffuse sources 
(e.g., sediment, nutrients), or from a natural or 
manmade alteration in the stream system. 

O&C Lands - Public lands granted to the Oregon 
and California Railroad Company and 
subsequently revested to the United States. 

Old growth - A forest containing many large trees 
with large snags and numerous large, down logs. 
There is a multi-layered canopy of several species. 
Some of the older trees are beginning to show 
signs of decadence. Small openings are scattered 
throughout the forest. In western Oregon, forests 
begin to have old growth characteristics at about 
200 years. 

Old-Growth Dependent - An animal species so 
adapted that it can exist only in old-growth 
forests. 

Operations Inventory - An intensive forest 
inventory which provides managers with 
information showing the location, acreage, 
silvicultural needs, and mortality-salvage or 
thinning needs within each section of public land. 



193 



Oregon Endangered Species Task Force - An 

Interagency task force represented by ODF&W, 
USFS, BLM, USF&WS, and Oregon State 
University, organized in 1973, to established 
habitat management guidelines for Oregon 
Endangered Wildlife Species. 

Outstanding Natural Areas - Areas of outstanding 
scenic splendor, natural wonder or scientific 
importance that merit preservation in their natural 
condition. The preservation of these resources in 
their natural condition is the primary management 
objective. Access roads, parking areas and public 
use facilities are normally located on the fringe of 
the area. The public is encouraged to walk into the 
area for recreation purposes wherever feasible. 

Paleontology - A science dealing with the life of 
past geological periods as known from fossil 
remains. 

Partial Cutting - Tree removal other than by 
clearcutting. 

Particulates - Finely divided solid or liquid 
particles in the air or in an emission; includes 
dust, smoke fumes, mist, spray and fog. 

Peak Flow - The highest amount of stream or river 
flow occurring in a year or for a single storm 
event. 

Perched Water Table - The surface of a local zone 
of saturation held above the main body of 
groundwater by an an impermeable layer or 
stratum, usually clay, and separated by the main 
body of ground water by an unsaturated zone. 

Permeability (soil) - The quality of a soil horizon 
that enables water or air to move through it; may 
be limited by the presence of one nearly 
impermeable horizon even though the others are 
permeable. 

Personal Income - The income received by all 
individuals in the economy from all sources; made 
up of wage and salary disbursements, proprietors 
income, rental income of persons, dividends, 
personal interest income, and the difference 
between transfer payments and personal 
contributions for social insurance. 

Phytoplankton - Suspended, floating or weakly 
swimming microscopic aquatic plants. 

Plankton - Organisms of relatively small size, 
mostly microscopic, that either have relatively 
small powers of locomotion or drift in the water 
subject to the action of waves and currents. 

Plant Community - An association of plants of 
various species found growing together in 
different areas with similar site characteristics. 

Plantation Release - Any action taken on an 
established commercial timber stand to control 



stand composition and promote dominance 
and/or growth of suitable tree species. Treatments 
may include mechanical or manual slashing of 
undesirable brush and tree species, herbicide, 
biological, or a combination of methods. Forest 
fertilization is not considered a release treatment. 

Plantation Stocking Maintenance - Any vegetation 
management action taken on an unestablished 
stand to promote the survival and establishment of 
suitable trees. Treatments may include using 
biological, mechanical, or manual weeding, 
mulching, herbicide or a combination of methods. 

Precommercial Thinning - Partial cuttings made in 
immature stands (10-25 years) in order to 
stimulate the growth of remaining trees by making 
available increased soil moisture, thereby 
increasing total yield from the stand. 

Prehistoric - Pertaining to that period of time 
before written history. 

Progeny Site - A test area for evaluating parent 
seed trees by comparing the performance of their 
offspring seedlings. 

Protection - Any action taken to protect suitable 
trees from adverse elements such as weather, 
animals, insects, and disease. Treatments include 
all practices which increase chances for survival 
and normal growth of desired tree species. 

Public Lands - Any land and interest in land 
owned by the United States within the several 
States and administered by the Secretary of the 
Interior through the Bureau of Land Management. 
May include public domain, O&C or acquired 
lands in any combination. 

Public Domain Lands - Original holdings of the 
United States never granted or conveyed to other 
jurisdictions. 

Recharge - Process by which water is added to the 
zone of saturation, as in recharge of an aquifer. 

Recreation Experience Opportunity - The 

opportunity for a person to realize predictable 
psychological and physiological outcomes from 
engaging in a specific recreation activity within a 
specific setting. 

Recreation Opportunity Setting - Combination of 
physical, biological, social, and managerial 
attributes present on a particular land area which 
influences the experience obtained by engaging in 
a specific recreation activity. 

Reforestation - Reestablishment of a tree crop on 
forest land. 

Regeneration - The renewal of a commercial tree 
crop, whether by natural or artificial means; also, 
the young crop itself. 



194 

Regeneration Period - The time it takes for a new 
commercial timber stand to become stocked 
following the date of a timber sale. 

Regulated Forest - A forest comprises a desired 
(usually even) distribution of age classes or tree 
sizes, when the growth equals the cut (at the 
highest level sustainable) and when the level of 
growing stock remains relatively constant. 

Research Natural Areas - Areas established and 
maintained for research and education. The 
general public may be excluded or restricted 
where necessary to protect studies or preserve 
research natural areas. Lands may have: (1) 
typical or unusual faunistic or floristic types, 
associations, or other biotic phenomena, or (2) 
characteristic or outstanding geologic, pedologic 
or aquatic features or processes. 

Riparian Habitat (Area or Zone) - Those terrestrial 
areas where the vegetation complex and 
microclimate conditions are products of the 
combined presence and influence of perennial 
and/or intermittent water, associated high water 
tables and soils which exhibit some wetness 
characteristics. 

Runoff - That part of precipitation, as well as any 
other flow contributions, which appears in surface 
streams, either perennial or intermittent. 

Sanitation/Salvage Cutting - Removal of individual 
trees killed or injured by fire, insects, disease, etc., 
and the removal of those trees likely to die prior to 
final harvest cut so as to utilize merchantable 
material. 

Sawlog - A log considered suitable in size and 
quality for producing sawn timber. 

Scenic Quality - The degree (high, moderate, and 
low) of visual harmony and variety within a 
landscape as compared to other units within the 
physiographic region. 

Scribner Log Rule - A log rule constructed from 
diagrams which shows the number of 1-inch 
boards which can be drawn in a circle 
representing the small end of a log; assumes a 
1/4-inch saw kerf, makes a liberal allowance for 
slabs, and disregards taper. 

Sediment Yield - The quantity of sediment, 
measured in dry weight or by volume, transported 
in water flowing through a stream cross-section in 
a given time. Consists of both suspended 
sediment and bedload. 

Sedimentary Rock - A rock formed from materials 
deposited from suspension or precipitated from 
solution and usually more or less consolidated; 
e.g., sandstone, shale, limestone and 
conglomerates. 



Seldom Seen - Portions of the landscape which 
are generally not visible from observer positions, 
or areas which are visible beyond 15 miles from 
those positions. 

Sensitive Species - Species not yet officially listed 
but which are undergoing a status review or are 
proposed for listing according to Federal Register 
notices published by the Secretary of the Interior 
or Secretary of Commerce, or according to 
comparable State documents published by State 
officials. (Reference Instruction Memo W.O. 
80-722.) 

Sensitivity Level(s) - The degree (high, medium, 
low) of user interest in scenic quality and concern 
about possible changes in the landscape features 
of an area. The two criteria for determining 
sensitivity levels are user volumes and user 
attitudes. 

Serai Stage - The relatively transitory communities 
within a sere. 

Sere - The whole series of communities which 
develop in a given situation. 

Shelterwood Cutting - A series of partial cuttings 
designed to establish a new crop of trees under 
the protection of the old. 

Silviculture - The art of producing and tending a 
forest. 

Siphon - A pipe which uses atmospheric pressure 
to transfer water from one point to another against 
gravity. 

Site Class - A measure of the relative productive 
capacity of an area for timber or other vegetation. 

Site Preparation - Any action taken in conjunction 
with a reforestation effort (natural or artificial) to 
create an environment which is favorable for 
survival of suitable trees during the first growing 
season. This environment can be created by 
altering ground cover, soil or microsite conditions, 
using biological, mechanical, or manual clearing, 
prescribed burning, herbicide or a combination of 
methods. 

Slash - The branches, bark, tops, cull logs, and 
broken or uprooted trees left on the ground after 
logging has been completed. 

Slump - Rotational failure of a discrete block of 
soil on a failure plane that is curved from top to 
bottom and from side to side. The block rotates 
downward and outward along this failure plane 
while remaining more or less intact. 

Smolt - A young salmon or trout that is migrating 
from freshwater to the ocean. 

Snag - A standing dead tree from which the leaves 
and most of the limbs have fallen. 



195 



Soil - The unconsolidated mineral and organic 
material on the immediate surface of the earth that 
serves as a natural medium for the growth of land 
plants. 

Soil Mapping Unit - A combination of soils, or 
miscellaneous land type or types that can be 
shown at the scale of mapping for the defined 
purposes of the survey; the basis for the 
delineations of a soil survey map. 

Soil Productivity - The capacity of a soil in its 
normal environment to produce a specified plant 
or sequence of plants under a specified system of 
management. 

Standard Industrial Classification (SIC) - An 

industrial classification system as defined by the 
Office of Management and Budget; defines 
industries in accordance with the composition and 
structure of the economy and covers the entire 
field of economic activity. Refer to lumber and 
wood products for an explanation of SIC 24. 

State Historic Preservation Officer (SHPO) - The 

official within each State, authorized by the State 
at the request of the Secretary of the Interior, to 
act as a liaison for purposes of implementing the 
National Historic Preservation Act of 1966. 

Stream Order - A system of stream classification. 
Each small unbranched tributary is a first order 
stream. Two first order streams join to make a 
second order stream. A third order stream has 
only first and second order tributaries, and so 
forth. 

Subsurface Flow - Horizontal movement of water 
through the soil profile. 

Succession - The orderly process of plant 
community change. Process by which one plant 
community will succeed another over time given 
the same climatic conditions. 

Surplus Inventory - A temporary (1-3 decades) 
excess of growing stock over and above that 
which is necessary to sustain the even flow level. 

Survival Cover - Cover required by animals to 
mitigate effects of a period of severe weather that 
cannot be met by thermal cover. The objective of 
survival cover is to provide a forest stand structure 
which will provide shade during times of high 
temperatures and intercept snow during severe 
storms and provide significant quantities of forage 
in the same stand. Stand closure should be at 
least 75 percent or more. 

Suspended Sediment - Sediment suspended in a 
fluid by the upward components of turbulent 
currents or by colloidal suspension. 

Sustained Yield - The yield that a forest can 
produce continuously at a given intensity of 
management. 



Teratogenicity - Ability of a substance to cause 
abnormal development of a fetus. 

Texture (soil) - The relative proportion of sand, silt 
and clay (expressed as percentages) in a soil; 
grouped into standard classes and subclasses in 
the USDA Soil Survey Manual. 

Thermal Cover - Cover used by animals to 
ameliorate effects of weather. For elk, a stand of 
conifer trees which are 40 feet or more tall with an 
average crown closure of 70 percent or more. For 
deer, cover may include saplings, shrubs or trees 
at least 5 feet tall with 75 percent crown closure. 

Timber Lands - See Forest Land. 

Timber Preservation Area - An area withdrawn 
from mineral entry and the timber base to protect 
the scientific and educational values of timber 
resources. 

Timber Production Base - Acres included in the 
calculation of the allowable cut (see Intensive 
Forest Management Lands). 

Timber Production Capability Classification 
(TPCC) - A classification system that identifies the 
commercial forest and base capable of producing 
timber on a sustained yield basis. 

True Fir - A member of the genus Abies, e.g., 
white fir (Abies concolor). Douglas-fir 
(Pseudotsuga menziesii) is not a true fir. 

Understory Species - Shade-tolerant plant species 
which characteristically grow beneath the forest 
canopy; e.g., blackberry and rhododendron. 

Unit Resource Analysis (URA) - A BLM planning 
document which contains a comprehensive 
inventory and analysis of the resources within a 
specified geographic area and an analysis of their 
potential for development. 

Visitor-day - Twelve visitor-hours, which may be 
aggregated continuously, intermittently or 
simultaneously by one or more persons. Visitor- 
days may occur either as recreation visitor-days or 
as non-recreation visitor-days. 

Visual Resource Basic Elements - The four major 
elements (form, line, color, texture) which 
determine how the character of a landscape is 
perceived. 

Visual Resources - The land, water, vegetation, 
animals and other features that are visible on all 
public lands (scenic values). 

Visual Resource Management (VRM) - The 

planning, design and implementation of 
management objectives to provide acceptable 
levels of visual impacts. 



196 

Visual Resource Management Classes - The 

degree of alteration that is acceptable within the 
characteristic landscape. Based upon the physical 
and sociological characteristics of any given 
homogeneous area and serves as a management 
objective to mitigate or avoid adverse visual 
impacts. Class I provides the highest level of 
protection for scenic values, and Class IV the 
lowest level. 

Volatilize - To evaporate; to change from a liquid 
to a gas. 

Water Quality - The combined physical, chemical 
and biological characteristics of water bodies. 

Watershed - The area drained by a given stream. 

Wetland or Wetland Habitat - Permanently wet or 
intermittently flooded areas where the water table 
(fresh, saline, or brackish) is at, near, or above the 
soil surface for extended intervals, where hydric 
wet soil conditions are normally exhibited, and 
where depths generally do not exceed two meters. 
Vegetation generally consists of emergent water- 
loving forms (hydrophytes) which require at least 
a periodically saturated soil condition for growth 
and reproduction. In certain instances, vegetation 
may be completely lacking. 

Wildlife Tree - A live tree remaining after timber 
harvest that can become a snag for cavity dwelling 
wildlife. 

Yarding - The act or process of conveying logs to 
a landing. 



197 



References Cited 



Adams, Darius M. 

1977. Effects of National Forest Timber Harvest on 
Softwood Stumpage, Lumber, and Plywood 
Markets: An Econometric Analysis. For. Res. Lab. 
Res. Bull. 15, Oregon State University, Feb. 1977. 

and Richard W. Haynes 



1980. The 1980 Softwood Timber Assessment 
Market Model: Structure, Projections, and Policy 
Simulations. Forest Science Monograph 22, 
Supplement to Forest Science, Vol. 26 No. 3. 

Richard W. Haynes, and David A. Darr 

1977. A Welfare Analysis of Long-Term Forest 
Products Price Stablization. American Journal of 
Agricultural Economics, Vol. 59, No. 4, Nov. 1977. 

Baker, Arthur 

1982. Personal communication. U.S. 
Environmental Protection Agency. Seattle, 
Washington. 

Beuter, John H., and Jeffery K. Handy 

1974. Research Paper 23. Forestry Research 
Laboratory, School of Forestry, Oregon State 
University, Corvallis, Oreg. 

Beuter, John H., K. Norman Johnson, and H. Lynn 
Scheurman 

1976. Timber for Oregon's Tomorrow: An Analysis 
of Reasonably Possible Occurrences. Research 
Bulletin 19, Forest Research Lab, Oregon State 
University, Corvallis, Oreg. 



Brown, George W. and J.T. Krygier 

1967. Changing Water Temperatures in Small 
Mountain Streams. In: Gibbons, D.R. and E.O. 
Salo, 1973. J. Soil and Water Conserv. 22(6): 242- 
244. 



1970. Effects of Clearcutting on Stream 
Temperature. Water Resour. Res. 6(4): 1133-1139. 
In: Gibbons, D.R. and E.O. Salo. 1973. An 
Annotated Bibliography of the Effects of Logging 
on Fish of the Western United States and Canada. 
USDA For. Serv. Gen. Tech. Rep. PNW-10. Pac. 
Northwest For. and Range Exp. Stn., Portland, 
Oreg. 



1971. Clearcut Logging and Sediment Production 
in the Oregon Coast Range. Water Resources 
Research, National Symposium on Watersheds in 
Transition, Am. Water Resour. Assoc. Proa, pp. 
1189-1199, Urbana, III. In: EPA 1973. Methods for 
Identifying and Evaluating the Nature and Extent 
of Non-point Sources of Pollutants. EPA, 
Washington, D.C. 

Bruner, William E. and Perry R. Hagenstein 

1981. Alternative Forest Policies for the Pacific 
Northwest. Study Module V, Forest Policy Project, 
Washington State University, Pullman, 
Washington. 



198 



Bunnell, F.L. and D.S. Eastman 

1976. Effects of Forest Management Practices of 
Wildlife in the Forests of British Columbia. In: Int. 
Union of Forest Res. Organizations, 16th 
Congress, Vol.1, pp. 631-689, Oslo, Norway. 

Burden, Patrick L. 

1977. The Effect of Declining Timber Supplies and 
Productivity Increases in the Forest Products 
Industries upon Employment in Douglas County, 
Oregon. M.S. Thesis Dept. of Geography, Oregon 
State University, Corvallis, Oreg. 

Burroughs, E.R., Jr., and B.R. Thomas 

1977. Declining Root Strength in Douglas-fir after 
Felling as a Factor in Slope Stability. USDA For. 
Serv. Res. Pap. INT-190, 27p. Intermt. For. and 
Range Exp. Stn., Ogden, Utah. 

Cameron, John J. and John W. Anderson 

1977. Results of the Stream Monitoring Program 
Conducted During FY 1977. Herbicide Spray 
Project, Coos Bay District. USDI, BLM, Coos Bay, 
Oregon. 

Chilcote, William W., G.P. Juday, R.W. Fonda, J.O. 
Sawyer and A.M. Wiedemann 

1976. A Survey of the Potential Natural Landmarks, 
Biotic Themes, of the North Pacific Border Region. 
A Report prepared for USDI, National Park 
Service. 

Christener, Jere 

1981. Changes in Peak Streamflows from Managed 
Areas of the Willamette National Forest. USDA 
Forest Service, Pacific Northwest Region, 
Willamette National Forest, Eugene, Oreg. 

Clutter, Jerome and Tommy R. Dell 

1978. Expected Yields of Pine Plantations on 
Prepared Sites, pp. 111-122. In: T. Tippen (ed.), 
Proceedings: A Symposium on Principles of 
Maintaining Productivity on Prepared Sites, 
Mississippi State University, March 21, 22, 1978. 
USDA For. Serv., Southern For. Exp. Stn., New 
Orleans, LA. 

Cromack, K., Jr., F.J. Swanson and C. C. Grier 

1979. A Comparison of Harvesting Methods and 
Their Impact on Soils and Environment in the 
Pacific Northwest. Forest Soils and Land Use, 
Proc. 5th N. Amer. Forest Soils Conf. Aug. 6-9, 
1978, USDA-FS. 

Coos-Curry-Douglas Economic Improvement 
Association 

1978, 1979. Comprehensive Economic 
Development Strategy. G. Anthony Kuhn, 
Executive Director, Roseburg, Oreg. 



Crouch, G.L. 

1974. Interaction of Deer and Forest Succession 
on Clearcuttings in the Coast Range of Oregon. In: 
Black, H.C. (ed.). 1974. Wildlife and Forest * 
Management in the Pacific Northwest, pp. 133-138. 
School of Forestry, Oregon State University, 
Corvallis, Oreg. 

DeCalesta, David S. and Gary Witmer 

1980. "The Relationship of Stand Development to 
Habitat Requirements of Elk in the Douglas-fir 
Region of the Coast Range of Oregon". Final 
Report, FS-PNW-Grant No. 18. Department of 
Fisheries and Wildlife, Oregon State University, 
Corvallis, Oreg. 

Dost, Frank N. 

1983. An Analysis of Human Health Hazards 
Associated with Some Herbicides Used in 
Forestry. Report prepared for USDI, BLM, Oregon 
State Office, Portland, Oreg. 

Douglas County Oregon 

1980. Douglas County Economic Element, 
Douglas County Comprehensive Plan. Roseburg, 
Oreg. 

Downing, Kent and Roger N. Clark 

1979. Users' and Managers' Perceptions of 
Dispersed Recreation Impacts: A Focus on Roaded 
Forest Lands. In: Recreational Impact on 
Wildlands: Conference Proceedings October 27- 
29, 1978. Seattle, WA. USDA, Forest Service; USDI, 
National Park Service. Pacific Northwest Region. 
33p. 

Edgerton, Paul J. 

1972. Big Game Use and Habitat Changes in a 
Recently Logged Mixed Conifer Forest in 
Northeastern Oregon. Proc. 52nd Annu. Conf. of 
West. Assoc, of State Fish and Game Comm., 
Portland, Oreg. 

and Burt R. McConnell 

1976. Diurnal Temperature Regimes of Logged 
and Unlogged mixed Conifer Stands on Elk 
Summer Range. USDA Forest Service Research 
Note PNW-277. USDA Forest Service, Portland, 
Oreg. 

Eligehausen, H., J. A. Guth, and H.O. Esser. 

1980. Factors Determining the Bioaccumulation 
Potential of Pesticides in the Individual 
Compartments of Aquatic Food Chains. 
Ecotoxicol. Envir. Safety. 4:134-157. 

Erman, Don C, J.D. Newbold and K.B. Roby 

1977. Evaluation of Streamside Buffer Strips for 
Protecting Aquatic Organisms. Contribution No. 
165. California Water Resources Center. University 
of California, Davis, Calif. 



1978. Projection of Future Job Losses in the 
Timber Industry in Douglas County due to timber 
supply declines and productivity increases. 
Roseburg, Oreg. 



199 



flacco, Paul Richard 

978. Projected Income and Employment Impacts 
if a Decline in the Timber Resource Base of a 
Highly Timber-dependent Economy. M.S. Thesis. 
)ept. of Agricultural and Resource Economics, 
Dregon State University, Corvallis, Oreg. 

r ranklin, Jerry F. and C.T. Dyrness 

973. Natural Vegetation of Oregon and 
Vashington. USDA For. Serv. Gen. Tech. Rep. 
'NW-8. Pac. Northwest For. and Range Exp. Stn., 
'ortland, Oreg. 

F.C. Hall, C.T. Dyrness and C. Maser 

972. Federal Research Natural Areas in Oregon 
ind Washington — A guidebook for Scientists and 
Educators. USDA, Forest Service, Pac. Northwest 
: or. and Range Exp. Stn., Portland, Oreg. 

Kermit Cromack, Jr., William Denison, Arthur 
i/lcKee, Chris Maser, James Sedell, Fred Swanson 
ind Glen Juday 

1981. Ecological Characteristics of Old-Growth 
Douglas-fir Forests USDA For. Serv. Gen. Tech. 
3ep. PNW-118, 48p. Pac. Northwest For. and 
3ange Exp. Stn., Portland, Oreg. 

: ranzreb, Kathleen E. and Robert D. Ohmart 

I978. The Effects of Timber Harvesting on 
3reeding Birds in a Mixed Coniferous Forest, 
Condor 80:431-441. 

: redriksen, R.L. 

1971. Impact of Forest Management on Stream 
A/ater Quality in Western Oregon. In: Pollution 
^atement and Control in the Forest Products 
ndustry, 1971-72 Proceedings, USDA, For. Serv. 



1972. Nutrient Budget of a Douglas-fir Forest on 
an Experimental Watershed in Western Oregon. 
Symposium proceedings — Research on 
:oniferous forest ecosystem, March 23-24. 

and R.D. Harr 



1979. Soil, Vegetation and Watershed Management 
of the Douglas-Fir Region. In: Forest Soils of the 
Douglas-Fir Region. Northwest Forest Soils 
Council; Washington State Cooperative Extension 
Service, Washington State University, Pullman, 
Wash. 

Fritschen, Bovee, Beuttner, Charlson, Monteith, 
Pickford, Murphy and Darley 

1970. Slash Fire Atmospheric Pollution. USDA For. 
Serv. Res. Pap. PNW-97. Pac. Northwest For. and 
Range Exp. Stn., Portland, Oreg. 

Froelich, H. 

1982. Personal communication. Soil scientist, 
professor Oregon State Univ., Corvallis, Oreg. 



Gibbons, D.R. and E.O. Salo 

1973. An Annotated Bibliography of the Effects of 
Logging on Fish of the Western U.S. and Canada. 
USDA For. Serv. Gen. Tech. Rep. PNW-10, Pac. 
Northwest For. and Range Exp. Stn., Portland, 
Oreg. 

Gratkowski, H. 

1974. Herbicidal Drift Control: Aerial Spray 
Equipment, Formulations, and Supervision. USDA 
For. Serv. Gen. Tech. Rep. PNW-14. Pac. 
Northwest For. and Range Exp. Stn., Portland, 
Oreg. 

and P. Lauterback 

1974. Releasing Douglas-firs from Varnishleaf 
Ceanothus. J. For. 72(3):150. 

Grier, Charles C. 

1982. Personal communication. Soil scientist, 
professor, University of Washington, Seattle, 
Wash. 

and Dale W. Cole 



1972. Elemental Transport Changes Occurring 
During Development of a Second-growth Douglas- 
fir Region. Symposium proceedings — Research 
on coniferous forest ecosystems, March 23-24. 

Hall, Alfred J. 

1972. Forest Fuels Prescribed Fire and Air Quality. 
USDA, For. Service, Pac. Northwest For. and 
Range Exp. Stn., Portland, Oreg. 

Hall, James D., and Richard Lantz 

1969. Effects of Logging on the Habitat of Coho 
Salmon and Cutthroat Trout in Coastal Streams. 
Cited in: The Impact of Timber Harvest on Soil and 
Water Resources, George W. Brown. Extension 
Bulletin 827, Oregon State University Extension 
Service, Corvallis, Oreg. 

Harper, James A. 

1969. Relations of Elk to Reforestation in the 
Pacific Northwest. In: Wildlife and Reforestation in 
the Pacific Northwest. Proc. of a Symposium held 
September 12-13, 1968, pp.' 67-71. Oregon State 
University, Corvallis, Oreg. 

Harris, D. D. 

1977. Hydrologic Changes after Logging in Two 
Small Oregon Coastal Watersheds. U.S. 
Geological Survey Water Supply Paper 2037. 

Hartung, R. 

1965. Effects of Oiling on Reproduction of Ducks. 
J. Wildl. Mgmt. 29(5): pp. 872-874. 



1966. Toxicity of Some Oils to Waterfowl. J. Wildl. 
Mgmt. 30(3): pp. 564-570. 

Hassleman, R. 

1979. Personal communication. Fisheries Planner 
and Fish Division Budget Coordinator. Oregon 
Dept. of Fish and Wildlife. Portland, Oreg. 



200 

Haynes, Richard W. 

1977. A Derived Demand Approach to Estimating 
the Linkage Between Stumpage and Lumber 
Markets. Forest Science Vol. 23, No. 2, June 1977. 

and Darius M. Adams 

1979. Impacts of RARE II Withdrawals on 
Softwood Prices, Consumption, and Production. 
Journal of Forestry, Vol. 78, No. 4, April 1979. 

Kent P. Connaughton, and Darius M. Adams 

1980. Stumpage Price Projections for Selected 
Western Species. Research Note PNW-367, Pac. 
Northwest For. and Range Exp. Stn., USDA, For. 
Serv., Portland, Oreg. 



1981. Projections of the Demand for National 
Forest Stumpage by Region; 1980-2030. Research 
Paper PNW-282, Pac. Northwest For. and Range 
Exp. Stn., USDA, For. Serv., Portland, Oreg. 

Heilman, Paul E. 

1981 . In: Forest Soils of the Douglas-fir Region. 
Edited by: Paul E. Heilman, Harry W. Anderson, 
David M. Baumgartner. Washington State 
University. 

Honey, William and Thomas C. Hogg 

1980. Cultural Resource Overview: Umpqua 
National Forest and Bureau of Land Management, 
Roseburg District. Oregon State University, Dept. 
of Anthropology, Corvallis, Oreg. 

Hoyer, G.E. 

1975. Measuring and Interpreting Douglas-Fir 
Management Practices. DfMR Report No. 26, 
Washington Department of Natural Resources, 
Olympia, Wash. 

Hughes, Dallas R. and Rudolph V. Edwards, Jr. 

1978. Granite Creek landslip survey. Umpqua 
National Forest. PNW Region, USDA, Roseburg, 
Oreg. 

Jenkins, Kurt and Edward Starkey 

1980. Rosevelt Elk of the Hoh Valley, Olympic 
National Park. Oregon Cooperative Park Studies 
Unit, Report 80-3, School of Forestry, Oregon 
State University, Corvallis, Oreg. 

Jensen, Harold 

1979. Personal communication. Douglas County 
Budget Director, Roseburg, Oreg. 

Ketcheson, Gary and Henry A. Froehlich 

1978. Hydrologic Factors and Environmental 
Impacts of Mass Movements in the Oregon Coast 
Range. Water Resources Research Institute, 
Oregon State University, Corvallis, Oreg. 



Kovner, J.L. 

1956. Evapotranspiration and Water Yields 
Following Forest Cutting and Natural Regrowth. 
Soc. Am. Foresters Proa, p. 106-110. In: R. Dennis 
Harr, Richard L. Fredriksen and Jack Rothacher. 

1979. Changes in Streamflow Following Harvest in 
Southwestern Oregon. Research Paper PNW-249, 
Pac. Northwest For. and Range Exp. Stn., USDA, 
Forest Service, Portland, Oreg. 

Lang, F.J. 

1980. Old-growth Forests of the Douglas-fir 
Region of Western Oregon and Western 
Washington: Characteristics and management. 
Jones and Stokes Associates, Inc., Sacramento, 
Calif. 61p. 

Lavy, T.L., J.D. Walstad, R.R. Flynn, and J.D. 
Mattice. 

1982. 2,4-D Exposure Received by Aerial 
Application Crews during Forest Spray 
Operations. Journ. Agric. Food Chem. 30:375-381. 

Leng, M.L., J.C. Ramsey, W.H. Braun, and T.L. 
Lavy. 

1982. Review of Studies with 2,4,5- 
trichlorophenoxyacetic Acid in Humans including 
Applicators under Field Conditions. Amer. Chem. 
Soc. Symp. Ser:182. 

Levno, Al and Jack Rothacher 

1969. Increases in Maximum Stream Temperatures 
after Slash Burning in a Small Experimental 
Watershed. USDA, For. Serv. Res. Note PNW-110. 
Pac. Northwest For. and Range Exp. Stn., 
Portland, Oreg. 

Lilly, John 

1981. Personal communication. Oregon 
Department of Transportation, Parks and 
Recreation Branch, Salem, Oreg. 

Lyon, L. Jack 

1979. Habitat Effectiveness for Elk as Influenced 
by Roads and Cover. Journal of Forestry, October 
1979. 

Marcum, C.L. 

1975. Summer-fall Habitat Selection and Use by a 
Western Montana Elk Herd. Cited in: Vehicle 
restrictions influence elk and hunter distribution in 
Montana, J.V. Basile and T.N. Lonner. Journal of 
Forestry, March 1979, p. 155-159. 

Maser, Chris, James M. Trappe, and Ronald A. 
Nussbaum 

1978. Fungal-Small Mammal Interrelationships 
with Emphasis on Oregon Coniferous Forest. 
Ecology 59(6):799-809. 



201 



Meslow, E. Charles 

1977. The Relationship of Birds to Habitat 
Structure — Plant Communities and Successional 
Stages. In: DeGraaf, Richard M. 1978. Proc. of the 
Workshop on Nongame Bird Habitat Management 
in the Coniferous Forests of the Western U.S., 
USDA, For. Serv. Gen. Tech. Rep. PNW-64. Pac. 
Northwest For. and Range Exp. Stn., Portland, 
Oreg. 

Morris, William G. 

1970. Effects of Slash Burning in Over Mature 
Stands of Douglas-fir Region. Forest Sci. 16: 258- 
270. 

Nash, R.G., P.C. Kearney, J.C. Maitlen, C.R. Sell, 
and S.N. Fertig. 

1982. Agricultural Applicators Exposure to 2,4- 
dichlorophenoxyacetic Acid. In: Pesticide 
Residues and Exposure. Amer. Chem. Soc. Symp. 
182:119-132. 

Newton, M., and L.A. Norris. 

1968. Herbicide Residues in Blacktail Deer from 
Forest Treated with 2,4,5-T and Atrazine. Proc. 
Western Weed Control Conf. Boise, pp. 32-34. 

Norris, L.A., et al. 

1974. The Behavior and Impact of Organic 
Arsenical Herbicides in the Forest: Final Report on 
Cooperative Studies. PNW Forest and Range Exp. 
Sta. USDA-Forest Service, Corvallis, Oreg. 

Norris, Logan A. 

1975. Behavior and Impact of Some Herbicides in 
the Forest. Pac. Northwest For. and Range Exp. 
Stn., Forestry Sciences Laboratory, Corvallis, 
Oreg. 

Oregon Department of Energy 

1980. Oregon's Energy Future, Fourth Annual 
Report (January 1, 1980) Salem, Oreg. 

Oregon Department of Environmental Quality 

1981. Oregon Air Quality Report-1981. Air Qual. 
Control Div., Portland, Oreg. 

Oregon Department of Fish and Wildlife 

1977. Streamfish Abundance, Distribution and 
Harvest Data. Portland, Oreg. 

Oregon Department of Forestry and National 
Weather Service 

1981. Annual Report, 1980 Oregon Smoke 
Management Plan; OSDF, Forest Protection 
Division; and NWS, Fire Weather Office; Salem, 
Oreg. 

Oregon Department of Human Resources, 
Employment Division 

1979, 1980. Annual Economic Report: Douglas 
County. Del Giglio, Labor Economist, Coos Bay, 
Oreg. 



Oregon Department of Transportation 

1977. Oregon Outdoor Recreation Needs Bulletin: 
Technical Document III of the Statewide 
Comprehensive Outdoor Recreation Plan. Parks 
and Recreation Branch, Salem, Oreg. 



1978. Oregon Outdoor Recreation Plan 1978, 
Review Draft. State Parks and Recreation Branch, 
Salem, Oreg. 

Perry, Charles and Robert Overly 

1977. Impacts of Roads on Big Game Distribution 
in Portions of the Blue Mountains of Washington. 
1972-1973. Bulletin No. 11, April 1977. Washington 
Game Department, Environmental Management 
Division, Applied Research Section, Olympia, 
Wash. 

Power, William E. 

1981a. Impacts of Subsoiling on Soil Compaction. 
Unpublished paper on file Salem District Office, 
BLM, Salem, Oreg. 



1981b. Impacts of Scarification on Early Tree 
Growth. Unpublished paper on file Salem District 
Office, BLM, Salem, Oreg. 

Pritchett, William L. 

1979. Properties and Management of Forest Soils. 
John Wiley and Sons, Inc. 

Rahm, CM. 

1980. Timber Supply Analysis and Baseline 
Simulations. Study Module lll-A, Forest Policy 
Project, Washington State University, Boeing 
Computer Service Company, Renton, Wash. 

Reynolds, Richard T. 

1971. Nest-site Selection of the Three Species of 
Accipiter Hawks in Oregon. Proc. Fish Wildl. 
Habitat Manag. Training Conf. USFS Training 
Conf., Eugene, Oreg. In: Literature Review of 
Twenty-Three selected Forest Birds. 

Rice, R.M. and S.A. Sherbin 

1979. Estimating Sedimentation from an Erosion 
Hazard Rating. PSW Forest and Range Experiment 
Station, Berkeley, Calif. 

Rothacher, Jack 

1970. Increases in Water Yield Following Clearcut 
Logging in the Pacific Northwest. Water Resources 
Research 6(2); 653-658. 

1971. Regimes of Streamflow and Their 
Modification by Logging, pp. 40-54. In: J. Morris 
(ed.), Forest Land Uses and Stream Environment. 
Oregon State Univ., Corvallis, Oreg. 

Row, Clark, H. Fred Kaiser and John Sessions 

1981. Discount Rate for Long-Term Forest Service 
Investments. Journal of Forestry, June 1981, pp. 
367-376. 



202 



Sandberg, D.V., J.M. Pierovich, D.G. Fox and E.W. 
Ross 

1978. Effects of Fire on Air. USDA, Forest Service, 
General Technical Report WO-9. 

Sandberg, D.V. 

1983. Personal communication. Pac. Northwest 
for. and Range Exp. Stn., USDA, Forest Service, 
Seattle, Wash. 

Seidel, Karen 

1981. Personal Communication. Bureau of 
Governmental Research and Service, University of 
Oregon, Eugene, Oreg. 

Sessions, Julian 

1979. Effects of Harvesting Technology upon 
Optional Stocking Regimes of Forested Stands in 
Mountainous Terrain. Doctoral dissertation, Dept. 
of Forest Management, Oregon State University, 
Corvallis, Oreg. 

Sikka, H.C., H.T. Appleton, and E.O. Gangstad. 

1977. Uptake and Metabolism of Dimethylamine 
Salt of 2,4-dichlorophenoxyacetic Acid by Fish. 
Journ. Agric. Food Chem. 25:1030-1033. 

Smithey, Douglas, A. Michael J. Wisdon and 
William W. Hines 

1982. Roosevelt Elk and Blacktailed Deer 
Response to Habitat Changes Related to Old- 
Growth Conversion in Southwestern Oregon. 
Presented at Northest Section of the Wildlife 
Society Annual Meeting Symposium: Old-Growth 
Forest — Wildlife Relationships. Juneau, Alaska. 

Sopper, William E. 

1975. Effects of Timber Harvesting and Related 
Management Practices on Water Quality in 
Forested Watersheds. J. Environ. Qual. 4 (l):24-29. 

Stere, David H., Blair R. Hopps and Gary 
Letterman 

1980. 1980 Oregon Timber Supply Assessment: 
Projects of future available harvests. Oregon State 
Forestry Department. 

Stevens, Joe B. 

1978. The Oregon Wood Products Labor Force: 
Job Rationing and Worker Adaptations in a 
Declining Industry. Oregon State University, Dept. 
of Ag. and Resource Econ., Corvallis, Oreg. 



1980. The Demand for Public Goods as a Factor in 
the Non-metropolitan Population Turnaround, p. 
115-135. In: D. Brown and J.M. Wardell (Ed.). New 
directions in urban-rural migration. New York: 
Academic Press. 



Swanson, D.O. 

1970. Roosevelt Elk - Forestry Relationships in the 
Douglas-fir Region of the Southern Oregon Coast 
Range. Ph.D. Thesis, Univ., of Michigan, Ann 
Arbor, Mich. 

Swanson, Frederick J. and C.T. Dyrness 

1975. Impact of Clear-cutting and Road 
Construction on Soil Erosion by Landslides in the 
Western Cascade Range, Oregon. Geology 
3(7):393-396. 

Mary M. Swanson and Chris Woods 

1977. Inventory of Mass Erosion in the Mapleton 
Ranger District, Suislaw National Forest (Final 
report). 

Thomas, Jack W. 

1979. Wildlife Habitats in Managed Forest of the 
Blue Mountains of Oregon and Washington. 
Agriculture Handbook No. 553, USDA, Forest 
Service. 

Tucker, Richard K. and D. Glen Crabtree 

1970. Handbook of Toxicity of Pesticides in 
Wildlife. USDI, Fish and Wildlife Serv., Res. Publ. 
No. 84. 

U.S. Department of Agriculture, Forest Service 

1980a. Twin Timber Sale — Wood Residue 
Utilization Study. Willamette National Forest. 



1980b. An Analysis of the Timber Situation in the 
United States 1952-2030 (Review draft). 

U.S. Department of the Interior, Heritage 
Conservation and Recreation Service 

1979. The Third Nationwide Outdoor Recreation 
Plan: The Executive Report. HCRS, Washington, 
D.C. 



1980. Nationwide Rivers Inventory: A Report on 
Natural and Freeflowing Rivers in the 
Northwestern United States. HCRS, Northwest 
Region, Seattle, Wash. 

U.S. Department of the Interior, Bureau of Land 
Management 

1959. Forest Engineering Handbook. Oregon State 
Office, Portland, Oreg. 



1975. Timber Management Final Environmental 
Impact Statement. Washington, D.C. 



1978. Vegetation Management with Herbicides 
Western Oregon. Final Environmental Statement. 
Oregon State Office, Portland, Oreg. 



1981. Public Goods, Residential Preferences and 
the Population Turnaround. Technical paper No. 
5624, Oregon Agricultural Experiment Station. 



1979a. BLM Facts - Oregon and Washington, 
1978. Oregon State Office, Portland, Oreg. 



203 



1979b. Young Growth Management Committee 
Report. Roseburg District, Roseburg, Oreg. 



1980a. Unit Resource Analysis, Roseburg District 
Office; Roseburg, Oreg. 



1980b. Planning Area Analysis, Roseburg District 
Office; Roseburg, Oreg. 



1980c. Proposed Management Framework Plan, 
Roseburg District Office, Roseburg, Oreg. 



1980d. Areas of Critical Environmental Concern 
Final Policy and Procedures Guidelines. 
Washington; D.C. 



1980e. BLM Facts — Oregon and Washington, 
1979. Oregon State Office, Portland, Oreg. 



1981a. Solutions to Operations and Reforestation 
Monitoring Systems (STORMS). Oregon State 
Office, Portland, Oreg. 



and Byron Thomas 

1981. Effects of skid roads on diameter, height, 
and volume growth in Douglas-fir. Soil Science 
Society of America Journal, Vol. 45, No. 3, May- 
June. 

Wight, Howard M. 

1974. Non-game Wildlife and Forest Management. 
In: Hugh C. Black, Editor, Wildlife and Forest 
Management in the Pacific Northwest. Proceeding 
of a Symposium. Forest Research Laboratory, 
School of Forestry, Oregon State University, 
Corvallis, Oreg. 

Wright, John 

1965. Callahan soil study. Umpqua National 
Forest, Tiller Ranger District. 

Youngblood, Douglas J. and Roger D. Fight 

1979. Natural Resource Policy: The Distributional 
Impact on Consumers of Changing Output Prices. 
Land Economics, Vol. 55, No. 1, Feb. 1979. 

Wolfe, H.R. 

1976. Field Exposure to Airborne Pesticides. In: Air 
Pollution from Pesticides and Agricultural 
Processes. R.E. Lee, Jr., Ed. CRC Press, 
Cleveland, OH. 



1981b. Final South Coast-Curry Ten-Year Timber 
Management Environmental Impact Statement. 
Oregon State Office, Portland, Oreg. 

U.S. Environmental Protection Agency 

1977. "Deficiencies in Pesticide Safety Lists 
Reported by EPA: Audit Requested." 
Environmental News, August 25, 1977. 
Washington, D.C. 



1978. Impact of Forestry Burning upon Air Quality. 
Final draft report prepared by GEOMET, Inc. for 
U.S. EPA, Gaithersburg, Md. 



1980. 2,4-D Fact Sheet. Region X, Pesticide and 
Toxic Substance Branch, Seattle, Wash. 

U.S. Government Printing Office 

1981 . Economic Report of the President together 
with the Annual Report of the Council of 
Economic Advisors, Washington, D.C. 

Weed Science Society of America 

1979. Herbicide Handbook of the Weed Society of 
America. Fourth edition. Champaign, III. 

Wert, Stephen P.., James A. Pomerening, T. Scott 
Gibson and Bryon R. Thomas 

1977. Soil Inventory, Roseburg BLM District USDI, 
BLM, Roseburg District, Roseburg, Oreg. 



205 



Index 



Criteria (Planning Objectives) 12, 154, 166 

Employment 21 , 49, 50, 53, 55, 56, 57, 84, 85, 87 

Erosion 20, 29, 30, 61 , 62, 63 

Fish Habitat 41 , 42, 74, 75 

Fishing 53, 74, 75 

Forest Structure 38, 66, 67, 68, 69 

Genetically Improved Stock 14, 15, 19, 67 

Habitat Corridors 13, 169 

Habitat Diversity 1 2, 1 5, 39, 40, 66, 70, 71 , 72, 73, 76 

Harvest Levels 3, 4, 12, 13, 14, 15, 16 

Herbicides 4, 5, 12, 14, 15, 17, 18, 19, 20, 21, 56, 65, 67, 73, 74, 81 

Hunting 53, 70, 71 , 76 

Income 50, 51, 53, 55, 56, 57, 84, 85, 86, 87 

National Register of Historic Places 1 6, 44, 78, 79 

Nationwide Rivers Inventory 23, 43 

O&C Revenues 51 , 52, 53, 55, 84, 86, 1 54 

Particulates 21 , 28, 60, 61 

Sediment Yield 20, 21 , 30, 63, 64, 65, 74 

Threatened and Endangered Species 13, 16 

Animals 42, 43, 75, 76, 154 

Plants 38, 39, 67, 68, 154 

Visual Resources 12, 21, 45, 79, 80, 81 

Water Yield 63, 64, 65 

Wilderness 45, 59 

Wildlife Habitat Alteration 21, 68, 69, 70, 71, 72, 73, 74, 179, 180, 181, 182, 183, 184, 185, 186, 187, 188 



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1982 

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